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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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