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interest as provided by law) that is at issue for Ms. Latos’
taxable year 1995; (2) it is only the unpaid assessed income tax
due shown in each of the income tax returns for Ms. Latos’
taxable years 1996 and 1997 (as well as assessed additions to tax
and interest as provided by law) that is at issue for each of
those years; and (3) it is only the unpaid assessed income tax
due shown in the 1998 return, increased by the income tax attrib-
utable to the mathematical error made in that return in calculat-
ing the total amount of exemptions allowable (as well as assessed
additions to tax and interest as provided by law), that is at
issue for Ms. Latos’ taxable year 1998.
It is Ms. Latos’ position that the Court should not sustain
the determinations with respect to her taxable years 1995 through
1998 set forth in the respective notices of determination upon
which these cases are based.13 In support of that position, Ms.
Latos argues that, because Mr. Anderson was an employee of the
owners of the boats on which he engaged in fishing activities
during each of the years 1995 through 1998, each such owner, as
Mr. Anderson’s employer, is responsible under section 3403 for
paying Ms. Latos’ unpaid 1995, 1996, 1997, and 1998 liabili-
13We do not have deficiency jurisdiction over the FICA tax
(or any interest thereon) with respect to Ms. Latos’ taxable year
1996. See Chatterji v. Commissioner, 54 T.C. 1402, 1405 (1970).
Consequently, we do not have jurisdiction over respondent’s
determinations in the 1995 through 1997 notice of determination
with respect thereto. See sec. 6330(d)(1).
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