Cynthia A. Bell - Page 9

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             The record does not explain the nature of this additional                
             payment.                                                                 
                  The tax reported on petitioner’s return for 1999 was                
             due and unpaid from April 15, 2000, until April 17, 2002.                
             By June 3, 2002, when respondent assessed the tax reported               
             on petitioner’s delinquent return for 1999, interest of                  
             $310.28 had accrued on the tax (i.e., $367.60, total                     
             interest assessed, less $57.32, interest related to the                  
             addition to tax under section 6654(a)(2) that was later                  
             reversed).  That amount was partially satisfied by an                    
             overpayment of tax from petitioner’s 2000 tax return in                  
             the amount of $39.25.  The balance, $271.03, continued to                
             accrue interest until March 29, 2004, when petitioner paid               
             $294.56, the balance of $271.03, plus additional assessed                
             interest of $23.53.                                                      
                  In passing, we note that the transcript of                          
             petitioner’s account for 1999 shows that additions to tax                
             under section 6654(a)(1) in the amount of $401.17 and under              
             section 6654(a)(2) in the amount of $115.89 were assessed                
             on June 3, 2002, and were reversed on June 3, 2002, and                  
             July 1, 2002, respectively, along with the interest related              
             thereto in the amount of $57.32.                                         









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