Patricia Agnes Williams, Debbie Wales, Next Friend - Page 3

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               The petition in this case was filed in response to a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320 (Notice of Determination).  Pursuant to sections 6320(c) and           
          6330(d), petitioner seeks review of respondent’s filing of a                
          Notice of Federal tax lien with respect to her income tax                   
          liability for 1990.  The issue for decision is whether                      
          respondent’s determination to proceed with collection action was            
          an abuse of discretion.                                                     
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  At the time the             
          petition in this case was filed, petitioner resided in Groves,              
               On September 6, 1994, the Internal Revenue Service (IRS)               
          received from petitioner and Ted Williams, her spouse, a Form               
          1040, U.S. Individual Income Tax Return, for 1990.  Petitioner              
          and her spouse claimed deductions of $11,217 for various expenses           
          on Schedule C, Profit or Loss From Business, but reported gross             
          receipts or sales of zero.  The return claimed a refund of                  
               The IRS disallowed the claim of petitioner and her spouse as           
          untimely, and later advised them that their return for 1990 had             
          been selected for examination.  The case of petitioner and her              
          spouse was transferred to Austin, Texas, at petitioner’s request.           

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