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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: This case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330.1 The issue for decision is whether respondent
may proceed with collection as so determined.
FINDINGS OF FACT
On November 12, 1998, respondent issued to petitioner
separate notices of deficiency for the 1995 and 1996 tax years.2
The notices reflected deficiencies of $1,123 and $3,518, for 1995
and 1996, respectively. The adjustments were based, for both
years, on disallowance of exemptions claimed by petitioner for
his two children and, for 1996, on disallowance of the earned
income credit and a change in filing status from head of
household to single. Petitioner and his wife, the children’s
mother, had separated in 1996. Petitioner received these notices
but did not file a petition for redetermination with the Tax
Court.
Petitioner was diagnosed with end stage renal disease in
August of 1999 and subsequently began kidney dialysis treatment.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code, as amended.
2 A statutory notice of deficiency for 1995 that had
previously been issued to petitioner on May 16, 1997, was
returned to respondent unclaimed and is not germane to this
proceeding.
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Last modified: May 25, 2011