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On May 20, 2002, respondent assessed the tax of $3,230 shown
in petitioners’ 2000 return, additions to tax under section
6651(a)(1) and (2) of $100 and $23.38, respectively, and interest
as provided by law. (We shall refer to any unpaid assessed
amounts with respect to petitioners’ taxable year 2000, as well
as interest provided by law accrued after May 20, 2002, as
petitioners’ unpaid 2000 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 2000 liability.
On April 15, 2002, petitioners jointly filed a return for
their taxable year 2001 (2001 return). Petitioners’ 2001 return
showed tax of $4,939, withholding credits of $4,732, and tax due
of $207. When petitioners filed their 2001 return, they did not
pay the tax due shown in that return.
On May 20, 2002, respondent assessed the tax of $4,939 shown
in petitioners’ 2001 return, an addition to tax under section
6651(a)(2) of $2.07, and interest as provided by law. (We shall
refer to any unpaid assessed amounts with respect to petitioners’
taxable year 2001, as well as interest provided by law accrued
after May 20, 2002, as petitioners’ unpaid 2001 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 2001 liability.
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Last modified: November 10, 2007