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This proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Code Section 6320(c) or 6330(d). This
case was set for trial at the New York, New York Trial Session
beginning on May 24, 2004. However, on April 9, 2004, respondent
filed a Motion for Summary Judgment under Rule 121, together with
exhibits. Petitioner did not file an objection to respondent’s
motion, even though the Court permitted her to do so. A hearing
on the motion was held in New York, New York. Both respondent
and petitioner appeared and were heard.
Background
Petitioner filed Federal income tax returns for taxable
years 1993, 1994, and 2000. With respect to taxable years 1993
and 1994, respondent conducted an examination of petitioner’s
returns. Respondent and petitioner reached a settlement for each
of these years which resulted in deficiencies. On April 15,
1996, and November 29, 1996, petitioner executed Forms 870,
Waiver of Restriction on Assessment and Collection of Deficiency
of Tax, for taxable years 1993 and 1994, respectively.
Respondent assessed the 1993 and 1994 tax deficiencies and
interest on June 17, 1996, and February 3, 1997, respectively.
With respect to taxable year 2000, petitioner failed to pay all
of the liability reported on her return as due. Accordingly,
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