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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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