Henry M. Lloyd - Page 6




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          and interest as provided by law accrued after November 10, 1997.5           
          (We shall refer to any unpaid and unabated assessed amounts with            
          respect to petitioner’s taxable year 1996, as well as interest as           
          provided by law accrued after April 13, 1998, as petitioner’s               
          unpaid 1996 liability.)                                                     
               Respondent issued to petitioner the notice and demand for              
          payment required by section 6303(a) with respect to petitioner’s            
          unpaid 1996 liability.                                                      
               On September 10, 1998, petitioner filed a return for his               
          taxable year 1997 (1997 return).  When petitioner filed his 1997            
          return, he did not pay the tax due shown in that return (i.e.,              
          $12,530).                                                                   
               On October 26, 1998, respondent assessed the tax due of                
          $12,530 shown in petitioner’s 1997 return, additions to tax under           
          sections 6651(a)(1) and (2) and 6654 of $563.85, $438.55, and               
          $228.11, respectively, and interest as provided by law for                  
          petitioner’s taxable year 1997.  (We shall refer to any unpaid              
          assessed amounts with respect to petitioner’s taxable year 1997,            
          as well as interest as provided by law accrued after October 26,            
          1998, as petitioner’s unpaid 1997 liability.)                               
               Respondent issued to petitioner the notice and demand for              
          payment required by section 6303(a) with respect to petitioner’s            

               5On Apr. 15, 1999, respondent credited a refund of $610 due            
          to petitioner for his taxable year 1998 against the liability for           
          petitioner’s taxable year 1996.                                             






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