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Petitioners resided in Catonsville, Maryland, at the time
they filed the petition in this case.
On or about April 15, 2001, petitioners jointly filed a
Federal income tax (tax) return (tax return) for their taxable
year 2000 (2000 return). Petitioners’ 2000 return showed tax of
$289,989, withholding credits of $18,634, estimated tax payments
of $96,780, and tax due of $174,575. When petitioners filed
their 2000 return, they paid only $1,000 of the tax due shown in
that return.
On June 11, 2001, respondent assessed the tax of $289,989
shown in petitioners’ 2000 return, an addition to tax under
section 6651(a)(2)1 of $1,735.75, and interest as provided by
law. On August 27, 2001, respondent made another assessment of
an addition to tax under section 6651(a)(2) of $2,734.02 and
interest as provided by law with respect to petitioners’ taxable
year 2000.
On or about March 25, 2002, petitioners filed an amended tax
return for their taxable year 2000 (petitioners’ amended 2000
return). On May 6, 2002, respondent processed petitioners’
amended 2000 return and abated tax for petitioners’ taxable year
2000 in the amount of $47,764. (We shall refer to any unpaid
assessed amounts with respect to petitioners’ taxable year 2000,
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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