- 8 -
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,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011