- 2 - 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, respondentPage: Previous 1 2 3 4 5 6 7 Next
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