Simone Joye - Page 2




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          determination that petitioner is liable for the additions to tax            
          under section 6651(a)(1)1 and (2) that respondent assessed for              
          each of petitioner’s taxable years 1987, 1988, and 1989?  We hold           
          that respondent did.                                                        
               (2)  Did respondent abuse respondent’s discretion in deter-            
          mining in the notice of determination to proceed to collect the             
          additions to tax under section 6651(a)(1) and (2) that respondent           
          assessed for each of petitioner’s taxable years 1987, 1988, and             
          1989?  We hold that respondent did not.                                     
               (3)  Did respondent abuse respondent’s discretion in deter-            
          mining in the notice of determination not to abate interest under           
          section 6404(e) for each of petitioner’s taxable years 1987,                
          1988, and 1989?  We hold that respondent did not.                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner resided in Bronx, New York, at the time she filed           
          the petition in this case.                                                  
               Petitioner filed a Federal income tax (tax) return (return)            
          for her taxable year 1987 on May 18, 1990.  In that return,                 
          petitioner showed $1,492 as tax for 1987.  As of April 15, 1988,            
          petitioner had a withholding credit of $961 with respect to that            
          tax.  On June 18, 1990, respondent timely assessed the following            


               1All section references are to the Internal Revenue Code in            
          effect at all relevant times.  All Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      




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