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Office hearing with petitioner in which petitioner raised only
the issue as to the includability in her income of alleged
discharge of indebtedness income.
On September 13, 2005, petitioner untimely filed with
respondent her 1996 individual Federal income tax return showing
a refund due to petitioner.
On October 21, 2005, respondent mailed to petitioner a
notice of determination sustaining respondent’s NFTL. In the
notice of determination, however, respondent’s Appeals Office
explained that respondent’s Audit Reconsideration Program is
willing to examine petitioner’s untimely filed 1996 individual
Federal income tax return and to make appropriate adjustments, if
any, to petitioner’s tax liability as previously determined by
respondent.
On November 18, 2005, petitioner timely filed the instant
action challenging only respondent’s notice of determination
sustaining respondent’s NFTL relating to the $24,629 1996 tax
deficiency respondent had assessed against petitioner. In her
petition, petitioner raises only the issue as to the
includability in her income for 1996 of discharge of indebtedness
income relating to the foreclosure sale of her home.
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Last modified: November 10, 2007