- 2 - to tax, and interest for 1988-89. Petitioner did not file tax returns for tax years 1988-2000. The issues for decision are: 1. Whether respondent was time barred from collecting taxes due for 1988-89. We hold that respondent is not. 2. Whether respondent’s refusal to consider petitioner’s offer in compromise because petitioner had not filed all required tax returns was an abuse of discretion. We hold that it was not. Section references are to the Internal Revenue Code in effect for the applicable years. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioner Petitioner is a self-employed real estate broker who lived in Gaithersburg, Maryland, when she filed the petition. She has been a real estate broker from before 1990 to the time of trial. She owned a business known as Sylvia International Realty. She had not filed income tax returns for tax years 1988 through 2000 as of the time of trial. B. Respondent’s Notice of Deficiency and Collection Activity Relating to Petitioner’s 1988-89 Tax Years Respondent issued a notice of deficiency to petitioner for tax years 1988-89, and petitioner timely filed a petition in this Court. Sheryl Fast (Fast), a paralegal for respondent, worked with petitioner in settling that case. In October and NovemberPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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