Gerald L. and Jessica P. Frey - Page 8

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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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