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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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Last modified: May 25, 2011