Davis and Lois Etkin - Page 3

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          liabilities were not fully paid either by withholdings or by any            
          payment submitted with the returns.  The balance owed in each               
          return is allocable to the income of both petitioners.                      
          Respondent has not determined a deficiency against either                   
          petitioner for the taxable years at issue.  Petitioners’ joint              
          income tax returns for the taxable years 1997 through 2000 showed           
          the following unpaid balances:                                              
                         Taxable Year   Unpaid Balance                                
                              1997      $18,504                                       
                              1998        28,448                                      
                              1999      12,421                                        
                              2000      14,359                                        
               Respondent assessed the following additions to tax under               
          sections 6654(a) and 6651(a)(2) in connection with the unpaid               
          balances:                                                                   
                                             Additions to Tax                         
               Taxable Year        Sec. 6651(a)(2)     Sec. 6654(a)                   
                    1997                $712.12        $701.00                        
                    1998           1,093.80            1,103.00                       
                    1999                248.42         525.22                         
                    2000                646.15         675.54                         

               Further, respondent assessed a $1,292.31 addition to tax for           
          failure to file a timely return for the taxable year 2000 under             
          section 6651(a)(1).1                                                        



               1Petitioners received an extension of time to file their               
          joint income tax return for the tax year 2000 until Oct. 15,                
          2001; however, they did not file it until Nov. 23, 2001.                    




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