John B. Cosgriff - Page 2

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          280.  The sole issue for decision is whether respondent abused              
          his discretion by denying petitioner’s request to abate interest.           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the accompanying exhibits are                  
          incorporated herein by this reference.  Petitioner resided in Las           
          Vegas, Nevada, at the time he filed his petition.                           
               For the year 1992, petitioner worked as a bartender at the             
          Las Vegas Hilton and conducted an auto sales business.                      
          Petitioner filed his 1992 Form 1040, U.S. Individual Income Tax             
          Return, on May 24, 1993.  Petitioner reported a business loss of            
          $16,504 related to auto sales for his business “Whole Sale Auto”.           
          On September 12, 1994, respondent notified petitioner in writing            
          that his 1992 Federal income tax return had been selected for               
          examination and requested that petitioner arrange an appointment            
          and produce records substantiating his tip income and certain               
          items from his Schedule C, Profit and Loss From Business.  On               
          November 14, 1994, petitioner provided respondent with his tip              
          diary but did not provide any information supporting his Schedule           
          C.  On November 23, 1994, respondent notified petitioner of                 
          proposed changes to his 1992 return.  The proposed changes                  

          206, secs. 3305(a), 3309(a), 112 Stat. 685, 743, 745.  Unless               
          otherwise indicated, all section references are to the Internal             
          Revenue Code and all Rule references are to the Tax Court Rules             
          of Practice and Procedure.                                                  

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