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Review for Abuse of Discretion
Petitioner must establish that respondent abused respon-
dent’s discretion in determining to proceed to collect the
additions to tax at issue under section 6651(a)(1) and (2) and
interest as provided by law for each of petitioner’s taxable
years 1987, 1988, and 1989. See Rule 142(a).
Additions to Tax Under Section 6651(a)(1) and (2)
Although not altogether clear, petitioner appears to contend
that respondent abused respondent’s discretion in determining 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 because: “I [petitioner] have been
the one to iniciate [sic] the cause of action in seeking to
rectify my situation with the IRS”. Petitioner offered the
following explanation of her position:
So, the issue is not so much that I didn’t want to
file taxes or I didn’t want to pay the taxes, but all
these years that have gone on, I don’t think that I
should be penalized when I have tried to, as evidenced
in all the exhibits, reach out to the IRS to have
someone sit with me and say, no, this [is] the law,
this is not the law, et cetera.
Respondent sent petitioner delinquency notices with respect
to her taxable year 1987 in July and September 1989 and in
February and March 1990.7 Thereafter, on April 24, 1990, peti
7Respondent also sent petitioner (1) a delinquency notice
with respect to petitioner’s unpaid liability for 1987 in June
(continued...)
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