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The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 (Notice of Determination). Pursuant to sections 6320(c) and
6330(d), petitioner seeks review of respondent’s filing of a
Notice of Federal tax lien with respect to her income tax
liability for 1990. The issue for decision is whether
respondent’s determination to proceed with collection action was
an abuse of discretion.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Groves,
Texas.
On September 6, 1994, the Internal Revenue Service (IRS)
received from petitioner and Ted Williams, her spouse, a Form
1040, U.S. Individual Income Tax Return, for 1990. Petitioner
and her spouse claimed deductions of $11,217 for various expenses
on Schedule C, Profit or Loss From Business, but reported gross
receipts or sales of zero. The return claimed a refund of
$1,926.
The IRS disallowed the claim of petitioner and her spouse as
untimely, and later advised them that their return for 1990 had
been selected for examination. The case of petitioner and her
spouse was transferred to Austin, Texas, at petitioner’s request.
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