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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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