- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011