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MEMORANDUM OPINION
WHERRY, Judge: This case arises from a petition for
judicial review filed in response to a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330.1
The issue for decision is whether respondent may proceed with
collection of tax liabilities for years 1995 through 1999 as so
determined.
Background
This case was submitted fully stipulated pursuant to Rule
122. The stipulations of the parties, with accompanying
exhibits, are incorporated herein by this reference.2
Petitioner is an artist who supported herself during the
1995 through 1999 tax years by taking odd jobs as an artist’s
model. She was born on May 21, 1951, and has, at all relevant
times, been single with no dependents.
On July 7, 1999, petitioner filed late Federal income tax
returns for 1995, 1996, and 1997 showing balances due. No
payments were remitted with the returns. Respondent assessed the
1 Unless otherwise indicated, section references are to
the Internal Revenue Code, as amended, and Rule references are to
the Tax Court Rules of Practice and Procedure.
2 Respondent objected to certain stipulations on the grounds
of relevancy and materiality. To the extent we have included
information from such stipulations to provide context, we deem
respondent’s objections moot in light of our opinion and the
resolution therein.
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