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7463(b), the decision to be entered is not reviewable by any
other court, and this opinion shall not be treated as precedent
for any other case.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioners resided in Cedar Rapids, Iowa, at the time they
filed the petition in this case.
On April 15, 1999, petitioners jointly filed a Federal
income tax (tax) return (return) for their taxable year 1998
(1998 return). Petitioners’ 1998 return showed tax of $4,226,
withholding credits of $3,201.67, and tax due of $1,024.33. When
petitioners filed their 1998 return, they did not pay the tax due
shown in that return.
On May 10, 1999, respondent assessed the tax of $4,226 shown
in petitioners’ 1998 return and interest as provided by law. On
various dates after May 10, 1999, petitioners made certain
payments with respect to their taxable year 1998. On May 2,
2005, respondent assessed a $256.09 addition under section
6651(a)(2) to petitioners’ tax for their taxable year 1998 and
interest as provided by law. (We shall refer to any unpaid
assessed amounts with respect to petitioners’ taxable year 1998,
1(...continued)
ences are to the Tax Court Rules of Practice and Procedure.
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