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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