Jeffrey R. Taylor - Page 1
















                                   113 T.C. No. 16                                    


                               UNITED STATES TAX COURT                                

                          JEFFREY R. TAYLOR, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15544-98.               Filed September 15, 1999.           

                    P was convicted of tax fraud.  P seeks an abatement of            
               interest under sec. 6404(e), I.R.C., for the period during             
               which a criminal investigation and prosecution took place.             
               P contends that the delay in proceeding with the civil case            
               while the criminal investigation and prosecution were                  
               pending was the result of a "ministerial act" by officers or           
               employees of the Internal Revenue Service within the meaning           
               of sec. 6404(e)(1)(A), I.R.C.                                          
                    Held:  R's decision not to proceed with the civil case            
               while the criminal investigation and prosecution were                  
               pending is not a ministerial act, and, accordingly, sec.               
               6404(e)(1)(A), I.R.C., is not applicable.  Therefore, R's              
               determination disallowing P's request for abatement of                 
               interest is sustained.                                                 

               Jeffrey R. Taylor, pro se.                                             
               Catherine J. Caballero, for respondent.                                








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