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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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