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Held: R's failure to abate interest was not an
abuse of discretion.
William Grant Lee, pro se.
Christian A. Speck, for respondent.
VASQUEZ, Judge: On November 5, 1996, respondent issued a
notice of final determination denying petitioner's claim to abate
interest pursuant to section 6404(e).1
The sole issue for decision is whether petitioner is
entitled to an abatement of interest pursuant to section 6404(e).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
At the time the petition was filed, petitioner resided in
Benicia, California, and his net worth did not exceed $2 million.
Petitioner has a college degree in petroleum engineering, and in
1980, he worked as a systems engineer.
During the late 1970's and early 1980's, William Kilpatrick
(Mr. Kilpatrick) promoted a tax shelter for the alleged purpose
of producing alternative fuels (Kilpatrick shelter). In 1980, on
account of the extraordinary income he received in that year,
petitioner invested in the Kilpatrick shelter by purchasing an
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
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