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On February 5, 2001, respondent refunded or credited4 to
petitioner the entire refund (i.e., $2,777.49) that he claimed in
his 1999 return, plus interest thereon.
On February 6, 2002, respondent issued to petitioner a
notice of deficiency (notice) with respect to his taxable year
1999. In that notice, respondent determined a deficiency in, an
addition under section 6651(a)(1) to, and an accuracy-related
penalty under section 6662(a) on petitioner’s tax for his taxable
year 1999 in the respective amounts of $9,319, $1,761, and
$1,864.
Petitioner did not file a petition in the Court with respect
to the notice relating to his taxable year 1999.
On July 22, 2002, respondent assessed petitioner’s tax, as
well as an addition to tax under section 6651(a)(1), a penalty
under section 6662(a), and interest as provided by law, for his
taxable year 1999. (We shall refer to those unpaid assessed
amounts, as well as interest as provided by law accrued after
July 22, 2002, as petitioner’s unpaid liability for 1999.)
On July 22, 2002, respondent issued to petitioner a notice
of balance due with respect to petitioner’s unpaid liability for
1999. On August 26, 2002, respondent issued to petitioner
4Respondent credited $500 of the refund claimed in peti-
tioner’s 1999 return in payment of a frivolous return penalty
under sec. 6702 that respondent imposed on petitioner with
respect to his 1999 return.
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Last modified: May 25, 2011