- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011