Doreen Boyd - Page 2

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          The Court agrees with and adopts the Opinion of the Special Trial           
          Judge, which is set forth below.                                            
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               ARMEN, Special Trial Judge:  On June 18, 1998, respondent              
          issued a notice of final determination denying petitioner's claim           
          to abate interest for the taxable years 1987, 1988, 1990, 1991,             
          and 1992.  Petitioner timely filed a petition under section                 
          6404(g)2 and Rule 280 for review of respondent’s denial of                  
          abatement of interest.  After a concession by petitioner,3 the              
          only issue for decision is whether respondent’s denial of                   
          petitioner’s request to abate interest for 1988 and 1990 was an             
          abuse of discretion.  We hold that it was not.                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioner resided in Camden, New Jersey, at the time               
          that her petition was filed with the Court, and her net worth did           
          not exceed $2 million at that time.                                         
               Petitioner filed her 1988 Federal income tax return on June            
          1, 1992.  She timely filed her 1990 return.  Respondent examined            
          petitioner’s 1988 and 1990 returns and issued petitioner a notice           

          2  Effective for tax years beginning after Dec. 31, 1997,                   
          sec. 6404(g) was redesignated as sec. 6404(i) by the Internal               
          Revenue Service Restructuring & Reform Act of 1998, Pub. L. 105-            
          206, secs. 3505(a), 3309(a), 112 Stat. 685, 743, 745.                       
          3  Petitioner no longer maintains a claim for abatement of                  
          interest with respect to taxable years 1987, 1991 and 1992.                 

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