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as petitioner’s unpaid 2001 income tax liability.)
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid 2001 income tax liability.
On April 15, 2003, petitioner filed an income tax return for
his taxable year 2002 (2002 income tax return). In his 2002
income tax return, petitioner showed tax due of $244, which he
did not pay when he filed that return.
On May 19, 2003, respondent assessed the income tax due of
$244 shown in petitioner’s 2002 income tax return, an addition to
tax under section 6651(a)(2) of $2.44, and interest as provided
by law. (We shall refer to any such unpaid assessed amounts with
respect to petitioner’s taxable year 2002, as well as interest
provided by law accrued after May 19, 2003, as petitioner’s
unpaid 2002 income tax liability.)
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid 2002 income tax liability.
On October 7, 2004, respondent filed a notice of Federal tax
lien with respect to petitioner’s unpaid 2001 income tax liabil-
ity and petitioner’s unpaid 2002 income tax liability.
On October 8, 2004, respondent issued to petitioner a notice
of Federal tax lien filing and your right to a hearing (notice of
tax lien) with respect to petitioner’s unpaid 2001 income tax
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