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Respondent issued to petitioner the notice and demand for
payment required by section 6303(a)2 with respect to petitioner’s
unpaid 1990 liability.
On April 15, 1992, petitioner filed a return for his taxable
year 1991 (1991 return). In that return, petitioner showed no
tax due.
At a time not disclosed by the record after petitioner filed
his 1991 return and before August 26, 1996, the IRS conducted an
examination with respect to petitioner’s taxable year 1991.
During that examination, the IRS proposed an increase in peti-
tioner’s tax of $13,380 for that taxable year, to which peti-
tioner agreed.
On August 26, 1996, respondent assessed the additional tax
of $13,380 to which petitioner had agreed and interest as pro-
vided by law for petitioner’s taxable year 1991. (We shall refer
to any unpaid assessed amounts with respect to petitioner’s
taxable year 1991, as well as interest as provided by law accrued
after August 26, 1996, as petitioner’s unpaid 1991 liability.)
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid 1991 liability.
On July 12, 1993, petitioner filed a return for his taxable
2All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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