Gary and Cynthia Stein - Page 5

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          additional tax of $5,642.  The assessment included an accuracy-             
          related penalty pursuant to section 6662, a failure to pay                  
          addition to tax pursuant to section 6651(a)(2), and interest for            
          taxable year 1997.                                                          
          2.  Taxable Year 1998                                                       
               For the taxable year 1998, petitioners timely filed their              
          Federal income tax return but failed to report all of their                 
          income and pay their full tax liability by the filing due date.             
          Respondent issued a notice of deficiency for taxable year 1998,             
          which petitioners subsequently defaulted.  As a result of the               
          default, respondent assessed an additional tax of $12,208.                  
          Petitioners were also assessed a dishonored check penalty, an               
          accuracy-related penalty pursuant to section 6662, a failure to             
          pay addition to tax pursuant to section 6651(a)(2), and interest.           
          Petitioners’ 1998 tax liability was ultimately paid on June 12,             
          2003.                                                                       
          3.  Taxable Year 1999                                                       
               For the taxable year 1999, petitioners failed to timely pay            
          their tax liability.  Petitioners were assessed a deficiency, an            
          addition to tax pursuant to section 6651(a)(2), and interest for            
          the taxable year 1999.  Petitioners’ 1999 tax liability was                 
          ultimately paid on June 26, 2000.                                           









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