Robert Banat - Page 2




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                                 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).                                           




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