Doris Lee Newsome - Page 2




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               Respondent’s motion to dismiss is based on the contention              
          that petitioner’s request for a section 6320 Appeals Office                 
          hearing was untimely.                                                       
               Respondent’s motion for summary judgment is based on the               
          contention that petitioner has not raised in her petition any               
          appropriate issue.                                                          

                                     Background                                       
               At the time the petition was filed, petitioner resided in              
          Staten Island, New York.                                                    
               On December 14, 1995, a nontax judgment of foreclosure was             
          entered relating to petitioner’s home, and in March of 1996 a               
          foreclosure sale of petitioner’s home occurred.  On June 10,                
          1998, petitioner was evicted from a subsequent home and later               
          moved to her current address.  At the time, petitioner did not              
          inform respondent of her current address.                                   
               For 1996, petitioner did not timely file an individual                 
          Federal income tax return.                                                  
               With wage and discharge of indebtedness income (relating to            
          the above foreclosure sale) reported to respondent by third                 
          parties, respondent prepared for petitioner a substitute 1996               
          individual Federal income tax return reflecting a total tax                 
          liability of $24,629.                                                       
               Based on the substitute return prepared by respondent, on              
          December 22, 1998, respondent mailed to petitioner (at the home             






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