- 2 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011