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computations and decision document accurately reflected the
settlement agreed to at the trial. Petitioner indicated that she
was dissatisfied with the settlement and wished to reopen the
negotiations and present additional information in an attempt to
reach a more beneficial settlement.
On September 22, 1998, respondent filed a motion for entry
of decision with the Court. Petitioner did not file an objection
to the motion. On November 4, 1998, the Court entered an order
and decision that, as relevant in this case, there was a
deficiency of $7,269 and a penalty due pursuant to section
6662(a) of $1,454, for 1994.
On February 19, 1999, respondent assessed the deficiency and
penalty using nonmaster file procedures for petitioner’s account
and adjusted Mr. Diarra’s nonmaster file account to be in line
with petitioner’s deficiency and penalty. Respondent sent
petitioner and Mr. Diarra notices reflecting these account
adjustments.
On April 5, 1999, respondent sent petitioner a fourth notice
demanding payment of the outstanding tax, penalty, and interest.
On May 3, 1999, petitioner paid $4,944 toward the 1994
deficiency and penalty. On May 5, 1999, the account was turned
over to respondent’s collection branch for active enforcement of
collection procedures because it was a delinquent account without
a formalized installment agreement.
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Last modified: May 25, 2011