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On September 10, 2007, we issued an opinion herein, Thomas
v. Commissioner, T.C. Memo. 2007-269, granting respondent’s
motion in limine and holding that petitioner in this collection
case could not raise an issue as to the amount of petitioner’s
2002 underlying Federal income tax liability.
On November 9, 2007, respondent filed the instant motion for
summary judgment as to petitioner’s claim for interest abatement
and for section 6673 penalties. On December 12, 2007, petitioner
filed an objection to respondent’s motion for summary judgment.
Background facts relevant to the instant motion were
generally set forth in our prior opinion as follows.
A securities firm reported to respondent on Forms 1099-B,
Proceeds From Broker and Barter Exchange Transactions, that in
2002 petitioner was paid 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 chose not to participate in respondent’s audit of
her 2002 individual Federal income tax return, and petitioner did
not submit information to respondent’s examining agent relating
to the reported income on the above Forms 1099-B.
Based on the $88,000 reported on the Forms 1099-B,
respondent recalculated petitioner’s 2002 income and determined a
$19,923 deficiency in petitioner’s 2002 Federal income taxes.
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Last modified: March 27, 2008