John Douponce - Page 1

          T.C. Memo. 1999-398                                                         

                               UNITED STATES TAX COURT                                

                            JOHN DOUPONCE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3756-98.            Filed December 7, 1999.                 

               John Douponce, pro se.                                                 
               Marilyn Devin, for respondent.                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               RUWE, Judge:  On December 23, 1997, respondent issued a                
          final determination disallowing petitioner's claim to abate                 
          interest.  Petitioner timely filed a petition under section                 
          6404(g)1 and Rule 280.  The issue for decision is whether                   

               1Sec. 6404(g) was redesignated as sec. 6404(i) by the                  

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