William M. Donovan - Page 2




                                        - 2 -                                         
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               CARLUZZO, Special Trial Judge:  On March 25, 1997,                     
          respondent issued a notice of final determination denying                   
          petitioner’s request to abate interest on deficiencies for the              
          years 1980 and 1981.  On June 16, 1997, respondent issued a                 
          notice of final determination denying petitioner’s request to               
          abate interest on deficiencies for the years 1982 and 1983.  In             
          response to each notice a timely petition was filed pursuant to             
          section 6404(g)2.  The two abatement cases were consolidated for            
          trial, briefing, and opinion.                                               
               The issue for decision is whether respondent’s failure to              
          abate accrued interest assessed on deficiencies for the years               
          1980 through 1983, inclusive, as requested in petitioner’s claims           
          for abatement was an abuse of discretion.                                   
          Background                                                                  
               Some of the facts have been stipulated and are so found.  At           
          the time the petitions in these cases were filed, petitioner                
          resided in New Canaan, Connecticut.                                         
               Although not readily apparent from the magnitude of the                
          record in these cases, which includes 109 exhibits and the                  




          2After the petitions were filed in these cases, sec. 6404(g)                
          was redesignated sec. 6404(i) by the Internal Revenue Service               
          Restructuring & Reform Act of 1998, Pub. L. 105-206, secs.                  
          3305(a), 3309(a), 112 Stat. 685, 743, 745.                                  





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