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In a Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330, dated March 21, 2006, respondent
concluded that it was appropriate to collect by levy petitioner’s
outstanding 1995 Federal income tax liability.
The issues for decision are: (1) Whether petitioner’s 1995
Federal income tax liability has been fully paid; and, if not,
(2) whether petitioner is entitled to an abatement of interest
and additions to tax included in that liability.
Background
Some of the facts have been stipulated and are so found.
Taking into account an extension to file, petitioner’s 1995
Federal income tax return was timely filed. On that return
petitioner reported an income tax liability of $2,231, all of
which is attributable to the tax on self-employment income, see
sec. 1401, and none of which was paid before the return was
filed.
According to respondent’s records, only $231 of the
$2,231 tax reported on the return was paid with the return.
Consequently, interest and additions to tax, as well as the tax
reported on the return, were assessed when the return was
processed on November 18, 1996.
In January 1997 respondent notified petitioner that her
then-outstanding 1995 liability was subject to collection by
levy. For reasons not entirely clear from the record, but
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