- 3 -
Petitioner did not file a petition in the Court with respect
to the 1999 notice of deficiency.
On February 24, 2003, respondent (1) assessed with respect
to petitioner’s taxable year 1999 the tax of $7,691 and additions
to tax under sections 6651(a)(1), 6651(a)(2), and 6654 of
$1,036.57, $806.22,4 and $204.74, respectively, that respondent
determined in the 1999 notice of deficiency, as well as interest
as provided by law on such assessed amounts, and (2) abated
certain of such assessed amounts. (We shall refer to any such
unpaid assessed amounts, as well as interest as provided by law
accrued after February 24, 2003, as petitioner’s unpaid 1999
notice of deficiency liability.)
On February 24, 2003, respondent issued to petitioner a
notice of balance due with respect to petitioner’s unpaid 1999
notice of deficiency liability.
Around March 18, 2003, petitioner’s return preparer sent
respondent Form 1040, U.S. Individual Income Tax Return, for
petitioner and his spouse Lauri Shannon (Ms. Shannon) for their
taxable year 1999 (1999 return) that petitioner and Ms. Shannon
had signed. Respondent filed that return sometime shortly after
respondent received it. In their 1999 return, petitioner and Ms.
Shannon reported total tax of $29,069 and tax due of $24,014.
When petitioner’s return preparer sent respondent the 1999 return
4See supra note 3.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011