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payment required by section 6303(a) with respect to Ms. Latos’
unpaid 1995 liability.
Ms. Latos and Mr. Anderson jointly filed Form 1040 for their
taxable year 1996 (1996 return). In their 1996 return, Ms. Latos
and Mr. Anderson showed income tax due of $4,924, which they did
not pay when they filed that return.7
On May 26, 1997, respondent assessed the income tax due
shown in the 1996 return, additions to tax under sections
6651(a)(2) and 6654 for Ms. Latos’ taxable year 1996, and inter-
est as provided by law. (We shall refer to any such unpaid
assessed amounts with respect to Ms. Latos’ taxable year 1996, as
well as interest as provided by law accrued after May 26, 1997,
as Ms. Latos’ unpaid 1996 liability.)
Respondent issued to Ms. Latos the notice and demand for
payment required by section 6303(a) with respect to Ms. Latos’
unpaid 1996 liability.
Ms. Latos and Mr. Anderson jointly filed Form 1040 for their
taxable year 1997 (1997 return). In their 1997 return, Ms. Latos
and Mr. Anderson showed income tax due of $3,491, which they did
not pay when they filed that return.8
On June 8, 1998, respondent assessed the income tax due
7The income tax due shown in the 1996 return does not in-
clude any self-employment tax.
8The income tax due shown in the 1997 return does not in-
clude any self-employment tax.
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Last modified: November 10, 2007