Angelo N. & Jo E. Grandelli - Page 10




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          as to what happened to the missing returns weighs in favor of               
          respondent.                                                                 
               Consequently, petitioners are not entitled to an abatement             
          of interest under section 6404(e) with respect to their 1997                
          income tax.  It follows that respondent’s failure to abate such             
          interest is not an abuse of discretion.                                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          






























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