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Background
This case involves an appeal from respondent’s determination
that petitioner is not entitled to an abatement of interest under
section 6404(e)(1). When the petition in this case was filed,
petitioner resided in Fountain Valley, California.
Petitioner timely filed his 1997 and 1998 Federal income tax
returns. Respondent selected the returns for examination. After
examining the returns, respondent concluded that petitioner had
unreported income and had improperly deducted travel expenses.
Accordingly, on March 21, 2001, respondent issued a notice of
deficiency to petitioner in which he determined deficiencies of
$48,206 and $11,672 for 1997 and 1998, respectively.
Additionally, respondent determined that petitioner was liable
for penalties under section 6662(a) of $9,513.40 and $2,224 for
1997 and 1998, respectively.
On June 11, 2001, petitioner filed a petition seeking a
redetermination of the deficiencies and penalties set forth in
the notice of deficiency. Trial was set for January 28, 2002.
On February 1, 2002, a decision reflecting a settlement between
petitioner and respondent (settlement) was entered by the Court.
Under the terms of the settlement, respondent conceded the
deduction for travel expenses, and petitioner conceded the
unreported income and the section 6662(a) penalties. The
decision contained a stipulation that interest would be assessed
on the deficiencies and penalties due from petitioner as required
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