Cynthia A. Bell - Page 2

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             accrued with respect to petitioner’s taxable years 1998                  
             and 1999.  Petitioner filed an imperfect petition and an                 
             amended petition for review of the Commissioner’s failure                
             to abate interest.  The case is presently before the                     
             Court to decide respondent’s motion for summary judgment.                
             Petitioner resided in New York, New York, at the time her                
             petition was filed.                                                      

                                      Background                                      
                  As we read her amended petition, petitioner complains               
             that, from November 25, 2002, in the case of her 1998                    
             return, and from November 11, 2002, in the case of her                   
             1999 return, she “was never notified by the IRS” of any                  
             discrepancies with respect to her returns.  The amended                  
             petition states:  “No correspondence, nor any other effort               
             was made to contact me about this matter [and] I had firmly              
             believed that all had been settled and resolved in                       
             reference to my IRS accounts.”  She complains that, in                   
             September 2003, she “was devastated” to learn “that my                   
             brokerage account had incurred back-up withholding and                   
             that a New York City school tax credit of $63.00 had been                
             withheld due to unpaid interest.”                                        
                  Petitioner asserts that the failure to contact her                  
             during this period of less than 10 months caused an                      
             unreasonable delay in her payment of the balances owed for               





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