- 2 - respondent’s determination to proceed with collection was an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time he filed the petition, petitioner resided in Dallas, Texas. In 1976, petitioner was hit by a car while riding his bicycle and suffered numerous permanent and irreversible injuries. Petitioner was diagnosed in 1998 with a broken back. Petitioner was self-employed during 1995, 1996, 1997, and 1998, the years in issue. Before and after the years in issue, petitioner was employed full time at Fusch-Serold and Partners. Since Fusch-Serold and Partners withheld a sufficient amount from petitioner’s pay, petitioner did not owe any additional amounts of tax for the years he was employed at Fusch-Serold and Partners. Respondent assessed the following amounts, which are in dispute: Additions to Tax Year Interest Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a) 1995 $4,459.61 $1,630.13 $289.80 $384 1996 6,874.01 2,173.95 676.34 428 1997 5,406.61 0.00 104.74 470 1998 825.40 0.00 91.96 66 On June 11, 2003, respondent mailed to petitioner a Final Notice of Intent To Levy for 1995, 1996, 1997, and 1998. On JulyPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011