- 2 -
The Court agrees with and adopts the opinion of the Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: On January 29, 1997,
respondent issued a notice of final determination denying
petitioner's claim to abate interest for the taxable year 1992.
The only issue for decision is whether petitioner is entitled to
an abatement of interest pursuant to section 6404(e).2
Petitioner contends that respondent abused his discretion by
failing to abate assessments of interest because (1) the income
that petitioner failed to report on his 1992 Federal income tax
return did not result from petitioner's error, (2) respondent
provided him with misinformation, and (3) respondent did not
promptly audit his income tax return for 1992 in light of the
disclosure on the return.
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. Petitioner resided in
Julian, California, when the petition in this case was filed.
During 1992, petitioner was employed as a systems analyst by
the United States Navy. In 1992, the Navy consolidated some of
its payroll processing centers. As a result of the
2 Section references are to the Internal Revenue Code in
effect for the year in issue.
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