Gregorio and Viviana Mankita - Page 2




                                        - 2 -                                         
          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.                                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011