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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 November
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