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around March 18, 2003, petitioner and Ms. Shannon did not pay the
tax shown due in that return.
On May 5, 2003, respondent assessed with respect to the
taxable year 1999 of petitioner and Ms. Shannon (1) tax of
$21,378 ($21,378 increase in 1999 tax), which was the difference
between the total tax (i.e., $29,069) that petitioner and Ms.
Shannon reported in their 1999 return and the amount of tax
(i.e., $7,691) that respondent determined in the 1999 notice of
deficiency and assessed on February 24, 2003, with respect to
petitioner’s taxable year 1999 and (2) additions to tax under
section 6651(a)(1) and (2) of $4,351.06 and $3,743.33, respec-
tively, attributable to the $21,378 increase in 1999 tax (in-
creases in the 1999 additions to tax), as well as interest as
provided by law on such assessed amounts. (We shall refer to any
such unpaid assessed amounts, as well as interest as provided by
law accrued after May 5, 2003, as petitioner’s5 unpaid 1999
return liability. We shall refer collectively to petitioner’s
unpaid 1999 notice of deficiency liability and petitioner’s
unpaid 1999 return liability, as well as interest as provided by
law accrued after February 24, 2003, and May 5, 2003, respec-
tively, as petitioner’s unpaid total 1999 liability.)
5This case involves only petitioner, and not Ms. Shannon.
For convenience, we shall sometimes refer only to petitioner, and
not to petitioner and Ms. Shannon.
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