Larry G. Schuster - Page 2




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          6404(i)2 and Rules 280-284.  The sole issue for decision is                 
          whether respondent abused his discretion by denying petitioner’s            
          request to abate interest.                                                  
          Background                                                                  
               The parties submitted this case fully stipulated.  The                 
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Great Falls,               
          Montana, at the time he filed his petition.                                 
               Petitioner timely filed his Federal income tax returns for             
          the years 1992 through 1995.  Respondent audited petitioner’s               
          income tax returns for all these years.  Respondent determined              
          deficiencies in petitioner’s income tax for the years 1992                  
          through 1995.3  Petitioner did not dispute those deficiencies,              
          and they were assessed.  Prior to June 12, 1997, petitioner made            
          various payments in partial satisfaction of his tax liabilities             
          for the years 1992, 1993, and 1994.  As of July 8, 1997,                    
          petitioner’s outstanding tax liabilities, consisting of                     
          assessments and additional accrued statutory additions, for 1992,           
          1993, and 1995, were $378.49, $1,124.76, and $128.23,                       
          respectively, for a total of $1,631.48.  As of July 7, 1997,                

               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect at the time that the petition           
          was filed in this case, and all Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      
               3Respondent also determined the estimated tax penalty                  
          applied for the taxable year 1995.  Petitioner does not dispute             
          the 1995 estimated tax penalty.                                             




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