Wyn Dee Stone - Page 3

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               On December 23, 2003, respondent issued to petitioner a                
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6330 (notice of determination) in which respondent                  
          sustained a proposed levy to collect the statutory interest and             
          addition to tax relating to petitioner’s 1998 tax liability.                
          Pursuant to section 6330(d), petitioner seeks review of                     
          respondent’s determination following an administrative hearing.             
               The issues for decision are:  (1)  Whether respondent abused           
          his discretion in failing to abate interest for tax year 1998,              
          and (2) whether respondent abused his discretion in failing to              
          abate the addition to tax under section 6651(a)(3)1 for tax year            
          1998.                                                                       
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts, and the attached exhibits are             
          incorporated by this reference.  Petitioner resided in Huntington           
          Beach, California, at the time the petition was filed.                      
          I.   Settlement Proceeds From Lawsuit                                       
               In 1997, petitioner was the plaintiff in a lawsuit against             
          Woody’s Wharf, and others (defendants), wherein she alleged                 
          claims of sexual harassment and discrimination.  In 1998,                   


               1  The parties have not clearly explained the nature of the            
          addition in issue.  We have concluded, based on an examination of           
          the entire record, that petitioner seeks an abatement of the sec.           
          6651(a)(3) addition to tax.                                                 





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