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decision is whether respondent abused his discretion in denying
petitioner’s request for abatement of interest.
FINDINGS OF FACT
The parties have stipulated some of the facts, which we
incorporate in our findings by this reference. When she filed
her petition, petitioner resided in Greenfield, California.
After their marriage in 1965, petitioner and her then-
husband, Frank Smith (Frank), owned and operated a farm in
Arkansas. In 1988, their farm was in financial straits, and
petitioner went to work in a laundry. In February 1990,
petitioner separated from Frank and moved to Greenfield,
California, where she worked as a live-in caregiver for the
elderly. Sometime in 1991 or 1992, petitioner and Frank
divorced.
1988 Tax Return
Petitioner and Frank filed a joint Federal income tax return
for 1988. On the return, they reported $59,925 of farm income
and $10,463 of wage income paid to petitioner. The return shows
a tax liability of $18,662, with credit claimed for $1,089 of
Federal income taxes withheld from petitioner’s wages,
resulting in $17,573 of tax owed (the 1988 liability). No
payment was included with the return.
In July 1989, respondent contacted petitioner and Frank in
writing regarding the 1988 liability. In response, petitioner
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