- 2 -
decision to be entered is not reviewable by any other court, and
this opinion should not be cited as authority.
This case arises from a petition filed in response to a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination) for the
taxable years 1999 and 2001 (years in issue). After the parties’
concessions concerning the amounts of earned income credit (EIC)
to which petitioner is entitled for the years in issue, the
issues for decision are:
(1) Whether respondent abused his discretion in failing to
abate interest for the years in issue. We hold that he did not.
(2) Whether petitioner is liable for additions to tax for
the years in issue. We hold that he is.
(3) Whether respondent abused his discretion in failing to
consider an installment agreement. We hold that he did.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time that the petition was filed, petitioner resided
in Burbank, California.
During the years in issue, petitioner was going through a
divorce and paying child support.
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