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to section 6330(d), petitioner seeks review of respondent’s
determination. The issue for decision is whether respondent’s
determination that collection action could proceed for Federal
income tax liabilities for the years at issue was an abuse of
discretion.
Background
The stipulation of facts and attached exhibits are
incorporated herein by this reference.2 Petitioner resided in
Honolulu, Hawaii, when he filed his petition.
Petitioner did not file Federal income tax returns for 1996,
1997, and 1998 and did not make estimated tax payments for these
years. Respondent filed substitutes for return on September 4,
2000, for 1996, 1997, and 1998. On February 23, 2001, respondent
mailed petitioner three notices of deficiency determining income
tax deficiencies of $22,037, $14,690, and $15,244 for 1996, 1997,
1998, respectively, and additions to tax under sections 6651(a)
1(...continued)
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. Amounts
are rounded to the nearest dollar.
2 On May 16, 2006, this Court’s order to show cause under
Rule 91(f), dated Apr. 28, 2006, was made absolute, and
the facts and evidence set forth in respondent’s proposed
stipulation of facts attached as Exhibit A to respondent’s motion
for order to show cause under Rule 91(f), filed on Apr. 27, 2006,
were deemed stipulated pursuant to Rule 91(f)(3) for purposes of
this case.
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