Linda Mitchell - Page 4

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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                  
               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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