T.C. Memo. 2000-141
UNITED STATES TAX COURT
ROBERT BANAT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2237-97. Filed April 14, 2000.
P filed a petition for a determination that R’s
failure to abate interest under sec. 6404(e), I.R.C.,
with respect to petitioner’s 1985, 1986, and 1987
taxable years was an abuse of discretion and for an
abatement order.
Held: P has not established any erroneous or
dilatory ministerial acts by R giving rise to the
assessment of interest after P was first contacted in
writing about the deficiency and before interest was
assessed.
Hedy P. Forspan, for petitioner.
Thomas J. Kerrigan, for respondent.
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