Joe Nathan Wright and Lola H. Wright - Page 2

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               Joe Nathan Wright and Lola H. Wright, pro sese.                        
               Alvin A. Ohm, for respondent.                                          

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  This case is before the Court for review of           
          respondent’s failure to abate interest.  Unless otherwise noted,            
          all section references are to the Internal Revenue Code of 1986,            
          as amended.                                                                 
                                  FINDINGS OF FACT                                    
               Some facts are stipulated and are so found.  The stipulation           
          of facts, with accompanying exhibits, is incorporated herein by             
          this reference.  At the time they filed the petition, petitioners           
          resided in Richardson, Texas.                                               
          Petitioners’ 1993 and 1994 Federal Income Tax Returns                       
               Petitioners timely filed Federal income tax returns for                
          their 1993 and 1994 taxable (calendar) years (the 1993 return and           
          the 1994 return, respectively).  On the 1993 return, petitioners            
          reported tax of $66,451 and prior payments of $2,000.                       
          Petitioners made an additional $2,000 payment when they filed the           
          1993 return.  On the 1994 return, petitioners reported tax of               
          $60,325 and prior payments of $2,000.  Petitioners made an                  
          additional $1,000 payment when they filed the 1994 return.                  
          Petitioners’ Offers in Compromise                                           
               On or before September 18, 1995, respondent received an                
          offer in compromise from petitioners dated August 30, 1995,                 




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