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as well as interest provided by law accrued after May 2, 2005, as
petitioners’ unpaid 1998 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 1998 liability.
On April 15, 2000, petitioners jointly filed a return for
their taxable year 1999 (1999 return). Petitioners’ 1999 return
showed tax of $3,649, withholding credits of $2,188, and tax due
of $1,461. When petitioners filed their 1999 return, they did
not pay the tax due shown in that return.
On May 22, 2000, respondent assessed the tax of $3,649 shown
in petitioners’ 1999 return, an addition to tax under section
6651(a)(2) of $10.61, and interest as provided by law. (We shall
refer to any unpaid assessed amounts with respect to petitioners’
taxable year 1999, as well as interest provided by law accrued
after May 22, 2000, as petitioners’ unpaid 1999 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 1999 liability.
On April 13, 2002, petitioners jointly filed a return for
their taxable year 2000 (2000 return). Petitioners’ 2000 return
showed tax of $3,230, withholding credits of $2,896, and tax due
of $334. When petitioners filed their 2000 return, they did not
pay the tax due shown in that return.
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Last modified: November 10, 2007