Edythe Fishbach - Page 2

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          with related additions thereto totaling approximately                       
          $24,860.85.2  Respondent has filed a motion for summary judgment            
          under Rule 121, which petitioner opposes.  We shall grant                   
          respondent’s motion for summary judgment.                                   
                                     Background                                       
               Petitioner failed to file a Federal income tax return for              
          1996.  On May 18, 1999, respondent mailed petitioner a notice of            
          deficiency, determining a deficiency for 1996 of $20,871, with              
          additions to tax under sections 6651(a)(1) and (2) and 6654(a) of           
          $2,286.90, $1,219.68, and $483.27, respectively.   On August 13,            
          1999, petitioner petitioned this Court to redetermine these                 
          amounts.  See Fishbach v. Commissioner, docket No. 13906-99S.               
          Because petitioner failed to prosecute her case, this Court                 
          dismissed it on February 20, 2001, and entered a decision for               
          respondent in the amounts stated in the notice of deficiency.               
               On February 6, 2003, respondent mailed to petitioner a                 
          Notice of Federal Tax Lien Filing and Your Right to a Hearing               
          Under IRC 6320.  Petitioner filed a request for the referenced              
          hearing and then ceased all communication with respondent, save             
          for one cryptic Form 656, Offer in Compromise, which stated as              
          its basis a doubt as to liability but contained no supporting               
          documentation.  Petitioner did not reply to respondent’s efforts            

               2 We say “approximately” as these amounts were computed                
          before the present proceeding and have since increased on account           
          of interest.                                                                





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