Mark S. & Lois A. Freme - Page 4




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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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