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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...)
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