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that return, petitioner and Ms. Hassell showed total tax and tax
due of $19,195. When petitioner and Ms. Hassell filed their 1992
return, they did not pay the tax shown due in that return.
On November 22, 1993, respondent assessed the tax of peti-
tioner and Ms. Hassell, as well as additions to tax under sec-
tions 6651(a)(2) and 6654 and interest as provided by law, for
their taxable year 1992.
On October 26, 1998, petitioner and Ms. Hassell jointly
filed Form 1040 for their taxable year 1997 (1997 return). In
that return, petitioner and Ms. Hassell showed total tax of
$18,324 and tax due of $9,673.96. When petitioner and Ms.
Hassell filed their 1997 return, they did not pay the tax shown
due in that return.
On October 26, 1998, respondent assessed the tax of peti-
tioner and Ms. Hassell, as well as additions to tax under sec-
tions 6651(a)(2) and 6654 and interest as provided by law, for
their taxable year 1997.
On January 15, 2002, the United States of America (United
States) commenced an action (District Court proceeding) against
Mr. Hassell and Ms. Hassell in the U.S. District Court for the
Northern District of Texas (District Court). In the District
Court proceeding, the United States sought, inter alia, to reduce
to judgment the tax liabilities of Mr. Hassell and Ms. Hassell
for their taxable years 1980 through 1984 and 1992.
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