Doreen Boyd - Page 4

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          for the period beginning 30 days after March 29, 1994, the date             
          on which this Court entered the decision in petitioner’s case,              
          and ending on the dates, respectively, when respondent made                 
          assessments for petitioner’s 1988 and 1990 tax years.4  In                  
          addition to the assessed deficiencies, the addition to tax for              
          1988, and the penalty for 1990, petitioner’s tax liabilities                
          included her assessed liabilities for Social Security taxes and             
          penalties for those two years.                                              
               Respondent issued payment notices for petitioner’s 1988 and            
          1990 assessments on February 13, 1995, July 24, 1995, and March             
          3, 1997.  Additionally, on November 12, 1997, pursuant to a                 
          request by petitioner, respondent issued petitioner a notice with           
          respect to each year in issue, providing a detailed explanation             
          of the interest and penalty charged to petitioner’s account.                
               On August 5, 1995, respondent filed a Notice of Federal Tax            
          Lien in Camden, New Jersey, with respect to unpaid assessments              
          due from petitioner for a number of years, including the two                
          years in issue.                                                             
               Pursuant to section 6404(a), the Commissioner is authorized            
          to abate the unpaid portion of the assessment of any tax or any             

          4  We note that the record does not indicate whether                        
          respondent issued a notice or demand for payment upon assessment            
          for either of the years in issue.  However, petitioner has not              
          alleged that such notice was not received nor does the record so            

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