- 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