- 2 - Background 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007