- 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
Last modified: May 25, 2011