- 2 -
Theodore W. Banis, Jr., pro se.
Ann M. Welhaf, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: Pursuant to section 6330(d), petitioner
seeks review of respondent’s determination to proceed with
collection of income taxes and additions to tax for calendar
years 1993 through 1996. During the trial, the parties made
concessions with respect to 1993-95. Respondent conceded that
collection is improper for 1993. Petitioner conceded, and
respondent agreed, that collection for 1994 is proper after
application by respondent of two credits to petitioner’s 1994
account in the amounts of $600 and $157.38. Petitioner also
conceded that collection is proper for 1995. The only issue
remaining in dispute is respondent’s determination to proceed
with collection for 1996.
Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure. All dollar
amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
and the supplemental stipulation of facts, with accompanying
exhibits, are incorporated herein by this reference.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011