Omar Urbina Pineda - Page 3

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          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.                                           







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