- 2 - shall grant respondent’s motion.2 Background The record establishes and/or the parties do not dispute the following. Petitioner resided in Chicago, Illinois, at the time she filed the petition in this case. On November 3, 1993, and February 3, 1993, respectively, respondent issued to petitioner notices of deficiency with respect to her taxable years 1988 and 1989, which she received. In the notice of deficiency (notice) relating to petitioner’s taxable year 1988, respondent determined a deficiency in, and additions under sections 6651(a)(1) and 6653(a)(1)3 to, peti- tioner’s Federal income tax (tax) for that year in the respective amounts of $2,368, $504, and $118. In the notice relating to petitioner’s taxable year 1989, respondent determined a defi- ciency in petitioner’s tax for that year of $3,217. Petitioner did not file a petition in the Court with respect 2Respondent concedes in respondent’s motion that “the col- lection actions taken against petitioner, as they relate to petitioner’s income tax liability for tax year 1993 are im- proper.” Respondent further states that “Respondent is in the process of abating the assessment of petitioner’s income tax liability and additions to tax for taxable year 1993.” In light of respondent’s concession with respect to petitioner’s taxable year 1993, we shall address the collection actions at issue only with respect to petitioner’s taxable years 1988 and 1989. 3All section references are to the Internal Revenue Code in effect at all relevant times. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011