- 2 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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