Henry M. Lloyd - Page 7




                                        - 7 -                                         
          unpaid 1997 liability.                                                      
               On April 15, 2003, petitioner filed a return for his taxable           
          year 2002 (2002 return).  When petitioner filed his 2002 return,            
          he paid $36,389 of the tax due shown in that return (i.e.,                  
          $37,248).                                                                   
               On June 16, 2003, respondent assessed the tax due, including           
          the $859 unpaid portion of that tax, shown in petitioner’s 2002             
          return, an addition to tax under section 6651(a)(2) of $12.88,              
          and interest as provided by law for petitioner’s taxable year               
          2002.  On January 19, 2005, petitioner paid $1,095.63 with                  
          respect to his taxable year 2002.6  On February 14, 2005, respon-           
          dent assessed a total of $216.42 consisting of an additional                
          amount of the addition to tax under section 6651(a)(2) of $150.33           
          and interest as provided by law accrued after June 16, 2003, of             
          $66.09 for petitioner’s taxable year 2002.  (We shall refer to              
          any unpaid assessed amounts with respect to petitioner’s taxable            
          year 2002,7 as well as interest as provided by law accrued after            
          February 14, 2005, as petitioner’s unpaid 2002 liability.)8                 

               6After petitioner’s payment on Jan. 19, 2005, petitioner’s             
          account with respect to his taxable year 2002 showed a credit of            
          $216.42 with respect to that year.                                          
               7It does not appear from the record that there is any unpaid           
          amount of liability with respect to petitioner’s taxable year               
          2002.  However, neither party makes any argument that there is no           
          unpaid amount of liability with respect to that year.                       
               8We shall refer collectively to petitioner’s unpaid liabili-           
                                                             (continued...)           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: March 27, 2008