Brenda H. Robinson - Page 2




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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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