- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011