William and Helen Woodral - Page 4




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               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             







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