Eldon Harvey Krugman - Page 3




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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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