- 8 - was not arbitrary, capricious, or without sound basis in fact or law. See Woodral v. Commissioner, supra at 23. Respondent reconsidered petitioner’s 1992 tax liability despite his failure to file a petition contesting the notice of deficiency. Thereafter, respondent exercised discretion in abating a substantial portion of the prior assessment. Any errors or delays were attributable to petitioner’s cancellation of scheduled appointments and his failure to timely produce requested information. Accordingly, we hold that respondent’s denial of petitioner’s claim to abate interest was not an abuse of discretion. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011