JOYE v. COMMISSIONER

SIMONE JOYE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

JOYE v. COMMISSIONER

No. 10338-00L

United States Tax Court

T.C. Memo 2002-14; 2002 Tax Ct. Memo LEXIS 14; 83 T.C.M. (CCH) 1091;

January 14, 2002, Filed

Respondent correctly determine in the notice of determination that petitioner is liable for the additions to tax. Respondent did not abuse respondent's discretion in determining in the notice of determination to proceed to collect the additions to tax under section 6651(a)(1) and (2). Respondent did not abuse respondent's discretion in determining in the notice of determination…