Shirley Renee Burton - Page 2

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          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.                                      





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