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September 17, 1997.1 However, these payments stopped in 1998
when petitioners again ran into severe financial difficulty.
Petitioners’ 1995 Federal income tax return reported tax of
$4,494, withholding credits of $805, and a balance due of $3,689.
On June 3, 1996, respondent assessed the tax reported by
petitioners in their 1995 return, along with penalties and
interest. Also on June 3, 1996, notice and demand for payment of
the 1995 income tax liability was sent to petitioners. However,
petitioners failed to pay the amount due.
Petitioners’ 1996 Federal income tax return reported tax of
$5,370, withholding credits of $2,242, and a balance due of
$3,128. On May 26, 1997, respondent assessed the tax reported by
petitioners in their 1996 return, along with penalties and
interest. Also on May 26, 1997, notice and demand for payment of
the 1996 income tax liability was sent to petitioners. However,
petitioners failed to pay the amount due.
Petitioners’ 1997 Federal income tax return reported tax of
$3,448, withholding credits of $1,081, and a balance due of
$2,367. On September 7, 1998, respondent assessed the tax
reported by petitioners in their 1997 return, along with
1Petitioners claim that this $3,200 payment was made to pay
off their 1996 tax liability. However, petitioner did not
present any evidence that the payment was earmarked for the 1996
tax liability. In fact, petitioners have not made any attempt to
get a copy of the check or any other evidence that would
substantiate their claim.
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