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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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