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The sole issue is whether respondent’s determination to
proceed with collection as to petitioner’s 1993 taxable year was
an abuse of discretion.
Background
At the time the petition was filed, petitioner resided in
Arlington, Texas.
On January 9, 1997, respondent sent petitioner a notice of
deficiency in his income tax for 1993. In response to this
notice, petitioner filed a timely petition with this Court. On
July 7, 1997, respondent made a master file assessment for the
amount of the 1993 deficiency.2 After realizing that a Tax Court
petition had been timely filed, respondent abated the master file
assessment on June 22, 1998.
On March 3, 1998, the Court entered a stipulated decision
that petitioner’s deficiency for 1993 was $5,954. Petitioner and
respondent both signed this decision document. On May 21, 1998,
respondent made a nonmaster file assessment of $5,954 to reflect
the stipulated decision.3
On February 2, 1999, respondent sent petitioner a Notice of
2 Master file assessments are assessments posted to the
master file computer in Martinsburg, W. Va. Assessment in
Appealed Cases, Internal Revenue Manual (IRM) (RIA), sec.
35.13.10.3 (2002).
3 Nonmaster file assessments are processed manually through
the service centers. Reference Guide: Examining Process, IRM,
sec. 104.3.1-1 (2002). The taxpayer’s tax account record
includes both master and nonmaster file assessments. Transcript
of Account Defined, IRM, sec. 8.17.3.1.1 (2002).
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