Henry M. Lloyd - Page 5




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          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 $95.28              








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