Nicholas & Carrie Cozzens - Page 2

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                                     Background                                       
               The record establishes and/or the parties do not dispute the           
          following.2                                                                 
               On or about March 17, 2000, petitioners filed a Federal                
          income tax (tax) return for each of their taxable years 1998                
          (1998 return) and 1999 (1999 return).  In their 1998 return,                
          petitioners reported, inter alia, total income of $76,031,                  
          taxable income of $63,308, total tax of $12,671, and tax due of             
          $5,031.54.  Petitioners did not remit any payment with their 1998           
          return.  In their 1999 return, petitioners reported, inter alia,            
          total income of $70,589, taxable income of $57,447, total tax of            
          $11,546, and tax due of $5,121.16.  Petitioners did not remit any           
          payment with their 1999 return.                                             
               On April 24, 2000, respondent assessed petitioners’ tax as             
          reported in each of their tax returns for 1998 and 1999, as well            
          as additions to tax under sections 6651(a) and 6654(a)3 and                 
          interest as provided by law for each of their taxable years 1998            
          and 1999.  (We shall refer to any such unpaid assessed amounts,             
          as well as interest as provided by law accrued after April 24,              
          2000, as petitioners’ respective unpaid liabilities for 1998 and            


               2The record does not disclose petitioners’ residence or                
          mailing address at the time they filed the petition in this case.           
               3All section references are to the Internal Revenue Code in            
          effect at all relevant times.  All Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      




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