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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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