- 2 - 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 homePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007