- 5 -
318; Willis v. Commissioner, T.C. Memo. 2003-302; O’Brien v.
Commissioner, T.C. Memo. 2003-290; Schulman v. Commissioner, T.C.
Memo. 2002-129. Petitioner’s OIC of $100 was not based on any
analysis. Petitioner failed to provide information or explain
how she arrived at her conclusions. Indeed, when the Court asked
petitioner to explain why she disagreed with respondent’s
analysis of her OIC, she failed to provide an adequate
explanation. We are satisfied that respondent did not abuse his
discretion in making his determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
To give effect to the foregoing,
An appropriate decision will
be entered for respondent.
Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011