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as well as interest as provided by law accrued after August 27,
2001, as petitioners’ unpaid 2000 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 2000 liability.
On or about August 13, 2002, petitioners jointly filed a tax
return for their taxable year 2001 (2001 return). Petitioners’
2001 return showed tax of $84,001, withholding credits of
$23,223, and tax due of $60,778. When petitioners filed their
2001 return, they did not pay the tax due shown in that return.
On September 9, 2002, respondent assessed the tax of $84,001
shown in petitioners’ 2001 return, additions to tax under sec-
tions 6651(a)(2) and 6654 of $2,303.19 and $1,519.45, respec-
tively, and interest as provided by law. (We shall refer to any
unpaid assessed amounts with respect to petitioners’ taxable year
2001, as well as interest as provided by law accrued after
September 9, 2002, as petitioners’ unpaid 2001 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 2001 liability.
On August 7, 2004, respondent sent to each petitioner a
final notice of intent to levy and notice of your right to a
hearing (notice of intent to levy) with respect to petitioners’
taxable year 2000. On the same date, respondent sent to each
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