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Held, further, R’s determination to proceed with
collection was not an abuse of discretion.
Raymond Wright, pro se.
Marie E. Small, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Pursuant to section 6330(d),1 petitioner
seeks review of respondent’s determination to proceed with
collection of his 1987 and 1989 tax liabilities.
FINDINGS OF FACT
None of the facts have been stipulated. At the time he
filed the petition, petitioner resided in New York, New York.
Deficiency Proceedings
Petitioner did not file returns for 1987 and 1989. On
October 29, 1993, respondent filed substitute returns for
petitioner’s 1987 and 1989 tax years.
On September 27, 1995, respondent sent petitioner a notice
of deficiency for 1987 and 1989 setting forth deficiencies of
$3,777 and $6,500, respectively, and additions to tax pursuant to
section 6651(a)(1) of $358 and $1,556, respectively.
On January 2, 1996, petitioner filed a petition with the
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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