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Federal income tax liabilities. The sole issue for decision is
whether respondent’s determination to proceed with the proposed
collection activity is an abuse of discretion. We hold it is
not.
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulation of facts, the
supplemental stipulation of facts, and the accompanying exhibits
are incorporated herein by this reference. Petitioner resided in
Watseka, Illinois, at the time he filed the petition in this
case.
Background
Petitioner and his wife, Tilda Boyer2 (collectively, the
Boyers), filed an untimely joint Federal income tax return for
1986 on November 16, 1987 (the 1986 return). On the basis of the
1986 return, respondent assessed $18,020 in income tax, $356 as
an addition to tax for failure to pay estimated tax under section
6654, $4,029 as an addition to tax for failure to file the 1986
return timely under section 6651(a)(1), $537 as an addition to
tax for failure to pay timely the amount shown as tax on the
return under section 6651(a)(2), plus interest (the 1986 tax
liability). On May 3, 1988, respondent filed a Notice of Federal
Tax Lien (Tax Lien Notice) regarding the 1986 tax liability.
2 Tilda Boyer did not join with her husband in filing the
petition and, therefore, is not a petitioner in this case.
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