Wyn Dee Stone - Page 8

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          2000, and petitioner did not file a timely petition.                        
          Accordingly, we review the determination for abuse of discretion.           
          Sego v. Commissioner, 114 T.C. 604, 610 (2000);  Goza v.                    
          Commissioner, 114 T.C. 176, 181 (2000).  Petitioner did not raise           
          collection alternatives or argue that the failure of respondent             
          to accept the OIC was an abuse of discretion.  Accordingly, we              
          need not consider whether the Appeals officer’s refusal to accept           
          the OIC submitted by petitioner was arbitrary, capricious, or               
          without sound basis in fact or law.  The only issues appear to be           
          an abatement of interest and an addition to tax.                            
         I.  Abatement of Interest                                                    
               If, as part of a section 6330 proceeding, a taxpayer makes a           
          request for abatement of interest, we have jurisdiction over the            
          taxpayer’s request for abatement that is the subject of the                 
          Commissioner’s collection activities.  Katz v. Commissioner, 115            
          T.C. 329, 340-341 (2000); Moore v. Commissioner, 114 T.C. 171,              
          175 (2000).  This Court may order an abatement of interest if the           
          Commissioner abuses his discretion in failing to abate interest.            
          Sec. 6404(i)(1).  The taxpayer must show that the Commissioner              
          exercised his discretion arbitrarily, capriciously, or without              
          sound basis in fact or law.  Woodral v. Commissioner, 112 T.C.              
          19, 23 (1999).                                                              
               As applicable for the year in issue, section 6404(e) permits           
          the Commissioner to abate interest with respect to any                      






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