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tax return (return) that they submitted to the Internal Revenue
Service (IRS).
On or about August 17, 1998, respondent prepared a
substitute for return for petitioners’ taxable year 1996.
On October 30, 1998, respondent issued a notice of
deficiency to petitioners with respect to their taxable year
1996. In that notice, respondent determined that for 1996
petitioners had a deficiency of $6,332, an addition to Federal
income tax (tax) under section 6651(a)(1)1 of $729.22, an
addition to tax under section 6651(a)(1) and (2) of $421.33, and
an addition to tax under section 6654 of $156. Petitioners did
not file a petition in the Court with respect to the notice of
deficiency relating to their taxable year 1996.
On June 7, 1999, respondent assessed petitioners’ tax of
$6,332, as well as additions to tax under sections 6651(a)(1) and
(2) and 6654 totaling $1,306.55 and interest as provided by law
of $751.08, for their taxable year 1996. (We shall refer to
those assessed amounts, as well as any interest as provided by
law accrued after June 7, 1999, as petitioners’ unpaid liability
for 1996.)
On June 7, 1999, respondent issued to petitioners a notice
of balance due with respect to petitioners’ unpaid liability for
1All section references are to the Internal Revenue Code in
effect at all relevant times.
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