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280. The sole issue for decision is whether respondent abused
his discretion by denying petitioner’s request to abate interest.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. Petitioner resided in Las
Vegas, Nevada, at the time he filed his petition.
For the year 1992, petitioner worked as a bartender at the
Las Vegas Hilton and conducted an auto sales business.
Petitioner filed his 1992 Form 1040, U.S. Individual Income Tax
Return, on May 24, 1993. Petitioner reported a business loss of
$16,504 related to auto sales for his business “Whole Sale Auto”.
On September 12, 1994, respondent notified petitioner in writing
that his 1992 Federal income tax return had been selected for
examination and requested that petitioner arrange an appointment
and produce records substantiating his tip income and certain
items from his Schedule C, Profit and Loss From Business. On
November 14, 1994, petitioner provided respondent with his tip
diary but did not provide any information supporting his Schedule
C. On November 23, 1994, respondent notified petitioner of
proposed changes to his 1992 return. The proposed changes
1(...continued)
206, secs. 3305(a), 3309(a), 112 Stat. 685, 743, 745. Unless
otherwise indicated, all section references are to the Internal
Revenue Code and all Rule references are to the Tax Court Rules
of Practice and Procedure.
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