Carol Lee Moore - Page 2




                                        - 2 -                                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, with accompanying exhibits, is                    
          incorporated herein by this reference.  At the time she filed her           
          petition, petitioner resided in Liverpool, New York.                        
               On April 12, 1994, respondent sent petitioner a notice of              
          deficiency determining a deficiency of $2,333 and a penalty under           
          section 6662(a) of $467 for 1992.  Respondent determined that               
          petitioner did not qualify for a filing status of “head of                  
          household”, was not allowed certain dependency exemptions, and              
          did not qualify for the earned income credit (EIC).  Petitioner             
          received the notice of deficiency but did not file a petition               
          with the Court.  Instead, on June 27, 1994, petitioner sent                 
          respondent a letter enclosing additional information and the                
          notice of deficiency.  Petitioner also contacted the Taxpayer               
          Advocate Office regarding her 1992 tax return; as a result,                 
          respondent reduced petitioner’s 1992 deficiency to $1,361 by                
          allowing petitioner the EIC.2                                               
               On July 31, 2000, respondent sent petitioner a Notice of               
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320.  On August 21, 2000, respondent received petitioner’s                 
          timely Request for a Collection Due Process Hearing.  In the                
          request, petitioner explained:  “I do not owe this tax.  Have               


               2  As of Feb. 13, 2002, petitioner owed $2,130.47.                     




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