Eldon Harvey Krugman - Page 13




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          respondent determine a deficiency in tax.  Sec. 6665(b); Meyer v.           
          Commissioner, 97 T.C. 555, 562 (1991).                                      
               We conclude that we lack jurisdiction under section 6404(g)            
          to decide petitioner's claim that respondent improperly refused             
          to abate the $147.21 addition to tax.                                       
          B.   Abatement of Interest                                                  
               1.   Contentions of the Parties                                        
               The parties agree that respondent's monthly payment notices            
          had incorrect payoff figures, but they disagree about the effect            
          of respondent's error.                                                      
               Petitioner contends that he is not liable for interest for             
          1985 because he fully complied with respondent's payment notices,           
          in which respondent repeatedly said the payments included                   
          interest.  He contends that respondent should not charge interest           
          after establishing payment terms which he fully met.  Petitioner            
          contends that respondent's failure to abate interest that accrued           
          from April 15, 1986, to April 11, 1993, is an abuse of                      
          discretion.                                                                 
               Respondent concedes that petitioner is entitled to an                  
          abatement of interest which accrued on his deficiency and                   
          addition to tax from April 12, 1993 (the date that respondent               
          first told petitioner that he owed tax and an addition to tax,              
          but incorrectly failed to notify him that he owed interest), to             
          August 9, 1995 (the day respondent corrected the error and first            






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