- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011