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1040A as a tax return. That was because respondent determined
that that document was frivolous.
On August 13, 2001, respondent assessed petitioners’ tax of
$8,035, as well as additions to tax under sections 6651(a)(1) and
(2) and 6654 totaling $1,509.43 and interest as provided by law
of $1,117.83, for their taxable year 1997. (We shall refer to
those assessed amounts, as well as any interest as provided by
law accrued after August 13, 2001, as petitioners’ unpaid
liability for 1997.)
On August 13, 2001, respondent issued to petitioners a
notice of balance due with respect to petitioners’ unpaid
liability for 1997.
On or about April 15, 2000, respondent received from
petitioners Form 1040 for their taxable year 1999 (1999 Form
1040). In their 1999 Form 1040, petitioners reported total
income of $0 and total tax of $0. Petitioners attached to their
1999 Form 1040 (1) respective Forms W-2 issued by the Virginia
Transportation Department, ESI, and ECPI College showing wages,
tips, and other compensation paid to Mr. Frey totaling $35,630.92
and (2) Form 1099-G, Statement for Recipients of Certain
Government Payments, showing unemployment compensation paid to
him of $1,596. Respondent processed and filed petitioners’ 1999
Form 1040 as a tax return.
On June 15, 2001, respondent issued a notice of deficiency
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