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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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