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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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