- 2 - OPINION DAWSON, Judge: This case was assigned to Special Trial Judge Carleton D. Powell pursuant to Rules 180, 181, and 183. All Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE POWELL, Special Trial Judge: This case involves the denial of a request by petitioner to abate interest under section 6404(e).1 On December 14, 1997, petitioner submitted two Forms 843 (Claim for Refund and Request for Abatement) to respondent. The requests pertained to the interest due on the deficiencies for the taxable years 1986 and 1987. By letter dated May 6, 1998, the requests were denied, and petitioner sought review by the Appeals Office. On July 9, 1998, the Appeals Office also denied the requests. On September 21, 1998, petitioner filed a petition for review of that determination with this Court. At the time that the petition for review was filed, petitioner resided in Tigard, Oregon. Background The facts may be summarized as follows. Petitioner filed joint Federal income tax returns with his then wife, Janet E. 1 Unless otherwise indicated, section references are to the Internal Revenue Code applicable for the periods involved.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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