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OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: Respondent issued a notice
of final determination denying petitioners’ claim to abate
interest for their 1989 and 1990 tax years. Petitioners filed a
timely petition for review of that determination with this Court.
The sole issue for decision is whether petitioners are entitled
to an abatement of interest pursuant to section 6404(e).2
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners’ legal
residence at the time the petition was filed was Cape Coral,
Florida.
Petitioners filed their 1989 and 1990 Federal income tax
returns timely. The Internal Revenue Service (IRS) thereafter
commenced an examination of petitioners’ 1989 and 1990 returns.
Despite several attempts by an IRS agent to meet with petitioners
with respect to their returns, petitioners ignored the requests.
Petitioners were then issued a revenue agent’s report, which they
also ignored, and that was followed by issuance of a notice of
deficiency. In that notice, respondent determined deficiencies
of $32,910 and $48,326 and accuracy-related penalties under
section 6662(a) of $6,582 and $9,665, respectively, for
2 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the periods involved.
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Last modified: May 25, 2011