Gerald L. and Jessica P. Frey - Page 3

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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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