-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.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011