- 5 - he did not pay the tax due shown in that return (i.e., $656). On May 29, 1995, respondent assessed the tax due of $656 shown in petitioner’s 1994 return, an addition to tax under section 6651(a)(2) of $6.56, and interest as provided by law for petitioner’s taxable year 1994. (We shall refer to any unpaid assessed amounts with respect to petitioner’s taxable year 1994, as well as interest as provided by law accrued after May 29, 1995, as petitioner’s unpaid 1994 liability.) Respondent issued to petitioner the notice and demand for payment required by section 6303(a) with respect to petitioner’s unpaid 1994 liability. On October 10, 1997, petitioner filed a return for his taxable year 1996 (1996 return). When petitioner filed his 1996 return, he did not pay the tax due shown in that return (i.e., $4,291). On November 10, 1997, respondent assessed the tax due of $4,291 shown in petitioner’s 1996 return, additions to tax under sections 6651(a)(1) and (2) and 6654 of $386.19, $133.38, and $202, respectively, and interest as provided by law for peti- tioner’s taxable year 1996. On April 13, 1998, respondent abated $480 of the assessed tax and $43.20 of the assessed addition to tax under section 6651(a)(1). On the same date, respondent also assessed an addition to tax under section 6651(a)(2) of $95.28Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008