Gregorio and Viviana Mankita - Page 7




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          their 1990 tax year.                                                        
               On August 14, 1997, respondent issued a final determination            
          denying petitioners’ interest abatement claim.3  Petitioners'               
          amended petition, with respondent’s final determination attached,           
          was filed on October 27, 1997.                                              
               As of May 13, 1998, petitioners owed $6,680.94 in tax and              
          interest.  Petitioners also owed about $1,910 under section                 
          6651(a) for the addition to tax for failing to timely file their            
          return and pay tax.  The amount of interest due on the addition             
          to tax under section 6651(a) was $1,456.94 on May 13, 1998.                 
                                       OPINION                                        
          A.   Abatement of Interest                                                  
               1.   Contentions of the Parties                                        
               Petitioners contend that respondent’s failure to abate                 
          interest on their 1990 tax liability from April 15, 1991, to the            
          present was an abuse of discretion.  Petitioners contend that too           
          much time passed from when respondent began the audit around June           
          1992 to when respondent issued the notice of deficiency on March            
          24, 1994.  Petitioners contend that Morrow should have settled              
          the case as quickly as Keenan did after she received the case.              
               Respondent contends that there were no errors or delays due            
          to ministerial acts by respondent and that respondent's refusal             


               3  On brief, petitioners and respondent argue that period in           
          dispute is from Apr. 15, 1991, to present.  We treat the issue              
          before us as stated in the briefs.                                          




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