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