- 2 -
The issue we must decide is whether respondent’s Appeals Office
abused its discretion in determining to proceed with collection
of petitioner’s tax liability for taxable years 1997 and 1998.
Background
At the time of filing the petition in the instant case,
petitioner resided in Leesburg, Virginia.
On June 22, 1998, petitioner filed his 1997 tax return
jointly with Sharon Lee Waters (Mrs. Waters), showing tax due
of $12,095.2 Petitioner had withheld payments of $15,000, and
respondent issued petitioner and Mrs. Waters a refund of $2,905
on June 22, 1998.
Respondent examined petitioner’s 1997 return and assessed
additional taxes on December 24, 2000, and November 3, 2003, of
$1,919, and $9,884, respectively. On October 24, 2005, the
outstanding balance, including interest and penalties, for
petitioner’s 1997 tax year was $14,763.21.
On November 29, 1999, petitioner filed his 1998 tax return
jointly with Mrs. Waters, showing tax due of $37,382.03.
Petitioner’s withholding for the 1998 year and payment submitted
with the return totaled $32,200. On January 27, 2000, petitioner
made a subsequent payment toward his liability for his 1998
taxable year of $5,868.02.
2Sharon Lee Waters is not a party to this case.
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