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