- 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