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to section 7430 and Rules 230, 231, and 232,1 filed April 14,
2000.
Neither party requested a hearing, and the Court concludes
that a hearing is not necessary for the proper disposition of
this motion. Although some facts appear in dispute, those facts
are essentially irrelevant to our resolution of this matter.
FINDINGS OF FACT
At the time the petition was filed petitioner resided in
Macedonia, Ohio.
Guild Mortgage Co. (Guild) issued petitioner a Form 1099-A,
Acquisition or Abandonment of Secured Property, and a Form 1099-
C, Cancellation of Debt, for petitioner’s 1996 taxable year. The
Form 1099-C indicated cancellation of debt income of $36,865.
Petitioner did not include this amount in income on his 1996
Federal income tax return.
Respondent mailed a CP2000 letter (commonly known as a 30-
day letter) to petitioner on January 13, 1998. The letter
proposed to increase petitioner’s 1996 taxable income to reflect
income from the cancellation of the debt. The proposed increase
resulted in an additional tax liability of $11,105 and the
imposition of an accuracy-related penalty under section 6662 of
$2,221.
1 Unless otherwise indicated, section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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