- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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