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respondent's denial of petitioner's request to abate interest was
an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation and attached exhibits are incorporated herein by
this reference. Petitioner resided in Los Angeles, California,
when the petition was filed. Petitioner filed delinquent Federal
income tax returns for 1988 and 1990 on or about August 25, 1993.
Petitioner filed a delinquent Federal income tax return for 1991
on or about August 2, 1994. The amounts of tax shown on the
returns, tax withheld, and interest and penalties assessed for
these years are as follows:
Credit for Late Filing Late Payment
Tax Reported Tax Penalty Penalty Interest
Year & Assessed Withheld Assessed Assessed Assessed
1988 $11,750 $8,313 $773.33 $859.25 $2,252.08
1990 13,105 11,776 299.03 199.35 369.03
1991 6,205 4,687 341.55 220.11 356.14
From May 1994 to September 1995, petitioner made monthly payments
of $500, all of which were applied to his 1988 liabilities. In
April 1995, a credit (from petitioner's 1994 taxable year) of
1(...continued)
Internal Revenue Service Restructuring & Reform Act of 1998 (RRA
1998), Pub. L. 105-206, secs. 3305(a), 3309(a), 112 Stat. 685,
743, 745. Unless otherwise indicated, section references are to
the Internal Revenue Code of 1986, as amended. Rule references
are to the Tax Court Rules of Practice and Procedure.
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