110 T.C. No. 3
UNITED STATES TAX COURT
JAMES G. & KATHERINE BOUREKIS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5894-97. Filed January 13, 1998.
R determined a deficiency for the taxable year
1981. The notice of deficiency did not include any
additions to tax or penalties; however, the notice did
include a statement that interest would accrue on the
deficiency. In a timely petition, Ps attempt to place
in dispute penalties and interest. Ps did not make a
written request with the IRS to abate interest;
however, they assert that they made an informal request
and that the notice of deficiency should be considered
a "final determination" not to abate interest under
sec. 6404(g). R filed a motion to dismiss for lack of
jurisdiction and to strike with respect to penalties
and interest.
Held: We lack jurisdiction to consider additions
to tax or penalties which were not determined in the
notice of deficiency.
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