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On April 4, 2004, petitioners jointly filed a return for
their taxable year 2002 (2002 return). Petitioners’ 2002 return
showed tax of $6,377, withholding credits of $4,238, and tax due
of $2,139. When petitioners filed their 2002 return, they did
not pay the tax due shown in that return.
On July 5, 2004, respondent assessed the tax of $6,377 shown
in petitioners’ 2002 return, additions to tax under sections
6651(a)(1), 6651(a)(2), and 6654 of $481.27, $99.67, and $29,
respectively, and interest as provided by law. (We shall refer
to any unpaid assessed amounts with respect to petitioners’
taxable year 2002, as well as interest provided by law accrued
after July 5, 2004, as petitioners’ unpaid 2002 liability.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid 2002 liability.
On April 15, 2004, petitioners jointly filed a return for
their taxable year 2003 (2003 return). Petitioners’ 2003 return
showed tax of $4,124, withholding credits of $2,642, and tax due
of $1,482. When petitioners filed their 2003 return, they did
not pay the tax due shown in that return.
On May 31, 2004, respondent assessed the tax of $4,124 shown
in petitioners’ 2003 return, additions to tax under sections
6651(a)(2) and 6654 of $14.82 and $41, respectively, and interest
as provided by law. (We shall refer to any unpaid assessed
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