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determinations therein. Ms. Latos and respondent were unable to
resolve administratively their differences with respect to Ms.
Latos’ taxable year 1995. As a result, on May 6, 1997, respon-
dent issued a notice of deficiency to Ms. Latos with respect to
that year (1995 notice of deficiency). In that notice, respon-
dent determined a deficiency in self-employment tax relating to
certain fishing activities of Mr. Anderson during 1995. Ms.
Latos did not file a petition with the Court with respect to the
1995 notice of deficiency.
On September 29, 1997, respondent assessed the self-employ-
ment tax determined in the 1995 notice of deficiency and interest
as provided by law. During January 1999, Ms. Latos discussed
that assessment with respondent’s problem resolution office. As
a result, respondent abated a portion of the self-employment tax
assessed for Ms. Latos’ taxable year 1995 so as to reduce the
amount of such self-employment tax liability to the amount of tax
under the Federal Insurance Contributions Act (FICA tax) for
which Ms. Latos and Mr. Anderson would have been liable if Mr.
Anderson had been treated as an employee for that year. (We
shall refer to any such unpaid and unabated assessed amounts with
respect to Ms. Latos’ taxable year 1995, as well as interest as
provided by law accrued after September 29, 1997, as Ms. Latos’
unpaid 1995 liability.)
Respondent issued to Ms. Latos the notice and demand for
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