Mark S. & Lois A. Freme - Page 3




                                        - 2 -                                         
          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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