Frank J. Gorgie and Rosalia Gorgie - Page 2




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          Petitioners meet the net worth limitations of section                         
          7430(c)(4)(A)(ii) and timely filed their petition pursuant to                 
          section 6404(i) and Rule 280.                                                 
               The only issue for decision is whether respondent's refusal              
          to abate interest for the period between May 8, 1989 to October               
          3, 1990, was an abuse of discretion.                                          
                                   FINDINGS OF FACT                                     
               Some of the facts have been stipulated for trial pursuant to             
          Rule 91.  The parties' stipulations are incorporated into this                
          Memorandum Opinion by reference and, accordingly, are found as                
          facts in the instant case.  Petitioners resided in Huntington                 
          Beach, California, when they filed their petition in the instant              
          case.                                                                         
               On May 8, 1989, the examination of petitioners' 1986 and                 
          1987 tax years was assigned to Internal Revenue Agent Patricia                
          Mazon.  The examination focused specifically on whether Frank                 
          Gorgie (petitioner) reported all income received from his                     
          employer National Energy Research Corp. (NERC).                               
               On May 12, 1989, Agent Mazon mailed an appointment letter to             
          petitioners.  Enclosed with the appointment letter was Form 4564,             
          Information Document Request Form (IDR) 1, which asked for, among             
          other things, books, records, bank statements and canceled checks             
          relating to income reported on petitioners' Schedule C, Profit or             
          Loss From Business, for the years under examination.  On May 22,              






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