- 4 -
On December 2, 1996, petitioners filed a petition (the 1996
petition) with the Court requesting the abatement of penalties
and interest relating to employment taxes for the taxable periods
ending June 30 and December 31, 1988 (the 1988 employment taxes).
On March 3, 1997, respondent received a Claim for Refund and
Request for Abatement (Form 843) from petitioners.
On March 17, 1998, respondent filed a motion to dismiss for
lack of jurisdiction (motion to dismiss) the 1996 petition on the
grounds that a notice of final determination not to abate
interest (notice of final determination) on the 1988 employment
taxes had not been issued to petitioners.
On March 26, 1998, the Commissioner issued a notice of final
determination to petitioners related to the 1988 employment
taxes. The Commissioner denied petitioners' request for
abatement.
On April 3, 1998, petitioners opposed respondent's motion to
dismiss and lodged with the Court a first amended petition for
review of failure to abate interest under section 6404 (the
amended petition).
In an order dated April 9, 1998, the Court granted
respondent's motion to dismiss the 1996 petition. Furthermore,
we ordered the amended petition be filed as petitioners' petition
for review of failure to abate interest under section 6404, and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011