Laurie Calder-Green, (2008)

United States Tax Court

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Laurie Calder-Green, (2008)

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

T.C. Summary Opinion 2008-126

UNITED STATES TAX COURT LAURIE CALDER-GREEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1705-06S. Filed September 22, 2008.

Laurie Calder-Green, pro se. Steven M. Webster, for respondent.

ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

The primary issue for decision in this collection review case is whether it was an abuse of respondent's discretion to deny effective tax administration relief to petitioner from her self-reported tax liability for the taxable year 2001. We hold that it was not. We must also decide whether it was an abuse of respondent's discretion not to abate interest on petitioner's underpayment of tax. We hold that it was not.

Background Some of the facts have been stipulated, and they are so found. We incorporate by reference the parties' extremely confusing stipulation of facts and moras...

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