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Petitioner strongly believes that IRC Section
6404(e)(1) does apply in this case, because there is
evidence in this case which shows that delays were not
attributable to Petitioner “Failure to file timely tax
returns” as Petitioner has been corresponding with the
IRS regarding these tax years since 1988. Addition-
ally, Petitioner is accused of raising at the Appeals
Conference a “W-4 argument [which] appears to have been
W-4 form since 1988. [Reproduced literally.]
OPINION
Petitioner does not dispute respondent’s determinations in
the notice of determination that respondent may proceed to
collect tax of $531 for 1987, $1,490 for 1988, and $170 for 1989.
Petitioner disputes only respondent’s determinations that respon-
dent may proceed to collect additions to tax under section
6651(a)(1) and (2) and interest as provided by law for each of
those years.4
4With respect to the additions to tax under sec. 6651(a)(1)
and (2) that respondent assessed for each of petitioner’s taxable
years 1987, 1988, and 1989, petitioner indicated at trial that
she disputes that she is liable for those additions to tax. On
brief, petitioner indicates that she seeks “abatement” of those
additions to tax. We construe petitioner’s position as a request
to review (1) whether she is liable for the additions to tax
under sec. 6651(a)(1) and (2) that respondent assessed for each
of her taxable years 1987, 1988, and 1989 and (2) whether if the
Court were to find that she is so liable, respondent may proceed
to collect such additions to tax.
With respect to the interest as provided by law for each of
petitioner’s taxable years 1987, 1988, and 1989, petitioner
indicated at trial and on brief that she seeks abatement of such
interest during the period 1990 to the present. We construe
petitioner’s position as a request to review respondent’s failure
(continued...)
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