Jeffrey R. Taylor - Page 6

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          Cir. 1995).  Subsequently, the Supreme Court denied petitioner's            
          petition for a writ of certiorari.  See Taylor v. United States,            
          551 U.S. 1222 (1996).                                                       
               On March 1, 1994, after petitioner's conviction and prior to           
          the so-called section 2255 proceedings, the District Counsel                
          notified the Examination Division that the criminal aspects had             
          been concluded, and the Examination Division was authorized to              
          proceed with the civil liability.  The revenue agent's report was           
          sent to petitioner on April 15, 1994.  Thereafter there were                
          several meetings with petitioner and the Examination Division.              
          In November 1994, the case was sent to the Appeals Office.  A               
          notice of deficiency was issued to petitioner and Ms. Taylor on             
          February 16, 1996, for the taxable years 1984 through 1988 after            
          the parties were unable to settle the matter satisfactorily.                
          Petitioner filed a petition with this Court at docket No. 8493-             
          96, and, on April 18, 1997, a stipulated decision was entered in            
          that case.  The petition filed herein seeks a redetermination of            
          the disallowance of the request for abatement of interest for the           
          1986 and 1987 taxable years.                                                
               Section 6404(e) provides in relevant part:                             
                    (1) In general.--In the case of any assessment of                 
               interest on--                                                          
                         (A) any deficiency attributable in whole or in               
                    part to any error or delay by an officer or employee of           

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