Ginger Harmornick - Page 4

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               On April 13, 1995, respondent issued separate notices of               
          deficiency to petitioner for 1991, 1992, and 1993.  In the                  
          notices, respondent determined deficiencies in, and additions to,           
          petitioner’s Federal income taxes as follows:                               
                  Additions to Tax                                                    
                Year   Deficiency    Sec. 6651(a)(1)   Sec. 6654(a)                   
               1991       $198            $100             ---                        
          1992     15,240           3,810            $663                             
          1993      5,781           1,445             239                             
          The deficiencies in income taxes were based on respondent’s                 
          determination that petitioner failed to report nonemployee                  
          compensation, interest income, and unemployment compensation as             
          reported to respondent by various third-party payors.                       
               Respondent’s records reflect that the notices of deficiency            
          were not returned undelivered to respondent by the U.S. Postal              
          Service.  Notably, petitioner has not denied that she received              
          the notices.                                                                
               C.  Assessment of Petitioner’s Liabilities                             
               Petitioner did not file a petition for redetermination with            
          this Court challenging the notices of deficiency.  See sec.                 
          6213(a).  Accordingly, on October 24, 1994, respondent assessed             
          the determined deficiency and additions to tax for 1990, as well            
          as statutory interest.  On that same day, respondent sent                   
          petitioner a notice of balance due, informing petitioner that she           
          had a liability for 1990 and requesting that she pay it.                    
          Petitioner failed to do so.  On November 13, 1995, respondent               

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