T.C. Memo. 2000-80
UNITED STATES TAX COURT
FRANK J. GORGIE AND ROSALIA GORGIE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20572-98. Filed March 9, 2000.
Frank J. Gorgie and Rosalia Gorgie, pro sese.
Jordan S. Musen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: Respondent determined that petitioners are
not entitled to an abatement of interest pursuant to section
6404(e)1 for their 1986, 1987, and 1988 taxable years.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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