Llwellyn Greene-Thapedi - Page 8

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          Amended Petition                                                            
               Petitioner subsequently filed an unopposed motion for leave            
          to file an amended petition in these Tax Court proceedings.  In             
          her amended petition, petitioner contended that the Appeals                 
          Office erred in determining that the proposed levy with respect             
          to her 1992 taxable year should proceed.  She also challenged her           
          liability for the 1992 deficiency and associated interest on the            
          ground that respondent had failed to make timely notice and                 
          demand for payment.                                                         
                                     Discussion                                       
               This Court previously dismissed this case as to petitioner’s           
          taxable years 1991 and 1997, leaving only 1992 at issue.                    
          Sometime after the petition was filed, respondent applied                   
          petitioner’s 1999 overpayment to offset her 1992 tax liability.             
          Consequently, respondent no longer claims any amount to be due              
          and owing from petitioner with respect to her 1992 income tax               
          account.  On supplemental brief respondent states that he                   
          “intends to take no further collection action with respect to               
          * * * [petitioner’s] 1992 tax liability”.  Accordingly,                     














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