- 2 - MEMORANDUM OPINION HALPERN, Judge: This case is before the Court for review of respondent’s failure to abate interest.1 By notice dated November 8, 1996, respondent made his final determination not to abate interest with respect to petitioner’s 1985, 1986, and 1987 taxable (calendar) years. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time the petition was filed, and all Rule references are to the Tax Court Rules of Practice and Procedure. At the time the petition was filed, petitioner resided in Brooklyn, New York. This case was submitted for decision without trial. See Rule 122. The parties have agreed to a stipulation of facts (the stipulation). The stipulation, with attached exhibits, is incorporated herein by this reference. Certain other exhibits were received into evidence. We shall not here repeat the stipulation or recite the contents of the other exhibits. We shall, however, summarize certain facts as an aid to understanding our discussion. 1 A prior report in this case appears at Banat v. Commissioner, 109 T.C. 92 (1997).Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011