Annie W. Nebres - Page 2

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          deficiencies in petitioner’s income tax, additions to tax, and              
          interest for 1996.                                                          
               The sole issue for decision is whether respondent’s                    
          determination to proceed with collection with respect to                    
          petitioner’s 1996 tax year was an abuse of discretion.  We hold             
          that it was not.                                                            
               Section references are to the Internal Revenue Code in                 
          effect for the applicable year.                                             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Petitioner resided in Ewa Beach, Hawaii, when she filed the            
          petition.                                                                   
               On January 14, 2000, respondent sent a notice of deficiency            
          for petitioner’s 1996 tax year to petitioner’s last known                   
          address; however, respondent concedes that petitioner did not               
          receive the notice of deficiency.  In the notice of deficiency,             
          respondent determined a deficiency in petitioner’s income tax of            
          $740 and disallowed petitioner’s claimed earned income credit of            
          $280.  Respondent computed petitioner’s tax using the tax tables            
          for married filing separately because petitioner was married and            
          did not file a joint return.                                                
               On May 29, 2000, respondent assessed petitioner’s tax and              
          interest for her 1996 tax year.  Also on that day, respondent               






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