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submitted a payment of $3,000. On August 18, 1994, petitioner
submitted a Form 2688, Application for Additional Extension of
Time To File U.S. Individual Income Tax Return.
Subsequently, petitioner failed to file timely his income
tax return for tax year 1993. On July 16, 1997, respondent filed
a substitute for return for petitioner. On October 17, 1997,
respondent sent to petitioner a notice of deficiency pertaining
to that year determining a tax deficiency of $6,845. On July 29,
1998, after receiving the notice of deficiency, petitioner
submitted a Form 1040, U.S. Individual Income Tax Return, for tax
year 1993 reporting a tax liability of $6,269 and claiming as a
payment credit the $3,000 he had paid with his Form 4868.
Petitioner did not file a petition with this Court with
respect to the notice of deficiency for the 1993 tax year. When
respondent assessed the deficiency on May 10, 1999, respondent
lowered the amount of petitioner's liability from the amount
stated in the notice of deficiency to an amount based upon the
Form 1040 submitted by petitioner.
Petitioner married Juanita Nicol in 1996. On August 28,
1999, petitioner and Mrs. Nicol (separately, petitioner and Mrs.
Nicol; together, the Nicols) submitted their joint 1997 Form 1040
to respondent showing tax due in the amount of $1,157. The
Nicols did not pay the tax due as shown on the return at the time
of filing. Respondent assessed the Nicols' tax liability for tax
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