-2-
with related additions thereto totaling approximately
$24,860.85.2 Respondent has filed a motion for summary judgment
under Rule 121, which petitioner opposes. We shall grant
respondent’s motion for summary judgment.
Background
Petitioner failed to file a Federal income tax return for
1996. On May 18, 1999, respondent mailed petitioner a notice of
deficiency, determining a deficiency for 1996 of $20,871, with
additions to tax under sections 6651(a)(1) and (2) and 6654(a) of
$2,286.90, $1,219.68, and $483.27, respectively. On August 13,
1999, petitioner petitioned this Court to redetermine these
amounts. See Fishbach v. Commissioner, docket No. 13906-99S.
Because petitioner failed to prosecute her case, this Court
dismissed it on February 20, 2001, and entered a decision for
respondent in the amounts stated in the notice of deficiency.
On February 6, 2003, respondent mailed to petitioner a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320. Petitioner filed a request for the referenced
hearing and then ceased all communication with respondent, save
for one cryptic Form 656, Offer in Compromise, which stated as
its basis a doubt as to liability but contained no supporting
documentation. Petitioner did not reply to respondent’s efforts
2 We say “approximately” as these amounts were computed
before the present proceeding and have since increased on account
of interest.
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Last modified: May 25, 2011