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Petitioners meet the net worth limitations of section
7430(c)(4)(A)(ii) and timely filed their petition pursuant to
section 6404(i) and Rule 280.
The only issue for decision is whether respondent's refusal
to abate interest for the period between May 8, 1989 to October
3, 1990, was an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties' stipulations are incorporated into this
Memorandum Opinion by reference and, accordingly, are found as
facts in the instant case. Petitioners resided in Huntington
Beach, California, when they filed their petition in the instant
case.
On May 8, 1989, the examination of petitioners' 1986 and
1987 tax years was assigned to Internal Revenue Agent Patricia
Mazon. The examination focused specifically on whether Frank
Gorgie (petitioner) reported all income received from his
employer National Energy Research Corp. (NERC).
On May 12, 1989, Agent Mazon mailed an appointment letter to
petitioners. Enclosed with the appointment letter was Form 4564,
Information Document Request Form (IDR) 1, which asked for, among
other things, books, records, bank statements and canceled checks
relating to income reported on petitioners' Schedule C, Profit or
Loss From Business, for the years under examination. On May 22,
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