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Rule 280.
The issues for decision are:
1. Whether respondent's denial of petitioners' claim to
abate interest relating to petitioners’ 1990 tax year was an
abuse of discretion. We hold that it was not.
2. Whether we have jurisdiction to review respondent's
failure to abate the late filing and payment penalty imposed by
section 6651(a). We hold that we do not.
Section references are to the Internal Revenue Code as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure. References to petitioner are to Gregorio Mankita.
FINDINGS OF FACT
Some of the facts are stipulated and are so found.
A. Petitioners
Petitioners are married and lived in Phoenix, Arizona, when
they filed the petition in this case.
Petitioner is licensed as a "contador publico" (public
accountant) in Mexico. He has been a tax preparer in the United
States since 1985.
In 1990, petitioners sold an office building in Los Angeles
and bought seven houses in Phoenix.
Petitioners applied for and received an extension to file
their 1990 return on August 15, 1991. Petitioners filed their
1(...continued)
3305(a), 3309(a), 112 Stat. 685, 743, 745.
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