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The issues for decision are:
1. Whether we have jurisdiction to decide: (a) Whether
petitioner is liable for additions to tax or penalties other than
those which he paid in installments, (b) whether respondent's
levy was improper, and (c) whether petitioner may offset his 1985
income tax liability with a refund from 1995. We hold that we do
not.
2. Whether respondent's denial of petitioner's request to
abate interest that accrued before April 12, 1993, was an abuse
of discretion. We hold that it was not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Grand Junction, Colorado, when he filed
the petition to abate interest. He graduated from the University
of Nebraska with degrees in architecture and construction
management. He worked in energy conservation before 1995 and in
home construction after 1995.
1(...continued)
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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