Patrick M. Shannon - Page 4

                                        - 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.                                                     




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