- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011