Silvia S. Rodriguez - Page 2

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          to tax, and interest for 1988-89.  Petitioner did not file tax              
          returns for tax years 1988-2000.                                            
               The issues for decision are:                                           
               1.  Whether respondent was time barred from collecting taxes           
          due for 1988-89.  We hold that respondent is not.                           
               2.  Whether respondent’s refusal to consider petitioner’s              
          offer in compromise because petitioner had not filed all required           
          tax returns was an abuse of discretion.  We hold that it was not.           
               Section references are to the Internal Revenue Code in                 
          effect for the applicable years.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Petitioner is a self-employed real estate broker who lived             
          in Gaithersburg, Maryland, when she filed the petition.  She has            
          been a real estate broker from before 1990 to the time of trial.            
          She owned a business known as Sylvia International Realty.  She             
          had not filed income tax returns for tax years 1988 through 2000            
          as of the time of trial.                                                    
          B.   Respondent’s Notice of Deficiency and Collection Activity              
               Relating to Petitioner’s 1988-89 Tax Years                             
               Respondent issued a notice of deficiency to petitioner for             
          tax years 1988-89, and petitioner timely filed a petition in this           
          Court.  Sheryl Fast (Fast), a paralegal for respondent, worked              
          with petitioner in settling that case.  In October and November             





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