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The issues for decision are:
1. Whether petitioner may contest her underlying tax
liabilities for tax years 1993 and 1994. We hold that she may
not.
2. Whether respondent’s determination to proceed with
collection with respect to petitioner’s 1993 and 1994 tax years
was an abuse of discretion. We hold that it was not.
3. Whether petitioner is liable for a penalty under section
6673. We hold that she is, in the amount of $2,500.
Section references are to the Internal Revenue Code in
effect for the applicable years.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Charlotte, North Carolina, when she
filed the petition in this case.
A. Petitioner’s Failure To File Tax Returns, Respondent’s
Notices of Deficiency for 1993 and 1994, and Petitioner’s
Correspondence With Respondent
Petitioner did not file income tax returns for 1993 and
1994. On January 26, 1996, respondent issued a notice of
deficiency to petitioner for 1993 in which respondent determined
that petitioner had a deficiency of $18,954 and was liable for
additions to tax of $4,711 under section 6651(a) and $791 under
section 6654(a). Petitioner received the notice of deficiency
for 1993 but did not file a petition in the Tax Court for 1993.
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