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petitioner is entitled to question the underlying merits of her
1993 and 1994 income tax liabilities.
FINDINGS OF FACT1
June H. Ginalski, petitioner, resided in Phoenix, Arizona,
at the time her petition was filed. Upon notification that
respondent had filed a Notice of Federal Tax Lien with respect to
petitioner’s 1993 and 1994 income tax liabilities, petitioner
timely requested a hearing before an Appeals officer. At the
hearing, petitioner sought to question the underlying merits of
her 1993 and 1994 tax liabilities which, to some extent, involved
whether amounts received by petitioner in connection with a
divorce were income to her. Petitioner did not wish to discuss
collection alternatives or other collection-related matters.
The Appeals officer refused to discuss the merits of the
underlying liabilities because petitioner had received a notice
of deficiency for her 1993 and 1994 tax years and had filed a
petition with this Court. After a trial on the merits of her
1993 and 1994 income tax, it was held in a Tax Court Summary
Opinion that the amounts petitioner received during 1993 and 1994
from her divorce proceeding were taxable to petitioner for those
years. Pursuant to this Court’s decision, respondent assessed
1 At trial, the parties stipulated facts and exhibits and
presented oral argument.
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