Yvonne Thomas - Page 2
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On March 26, 2007, a hearing was held on these motions in
Los Angeles, California. Respondent’s motion is based on
section 6330(c)(2)(B) that limits considerably the scope of our
review of respondent’s Appeals Office determinations in
collection matters. Petitioner’s motions are based on a variety
of theories and statutory provisions.
A securities firm reported to respondent on Forms 1099-B,
Proceeds from Broker and Barter Exchange Transactions, that
petitioner in 2002 realized income of approximately $88,000 on
the sale of stock.
On her 2002 individual Federal income tax return filed with
respondent, petitioner reported only nominal income and no income
from the sale of stock.
Petitioner did not participate in the audit of her 2002
individual Federal income tax return that was conducted by
respondent, and petitioner did not submit information to
respondent’s examining agent relating to the income reported on
the above Forms 1099-B.
Based on the $88,000 reported on the Forms 1099-B,
respondent recalculated petitioner’s income and determined a
$19,923 deficiency in petitioner’s 2002 Federal income taxes.
On February 22, 2005, respondent mailed to petitioner a
notice of deficiency reflecting the above $19,923 tax deficiency
and a $3,900 section 6662 accuracy-related penalty.
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Last modified: November 10, 2007