- 17 - H. Petitioner’s Allegations Regarding “The Box” The record in this case includes a copy of a mailing label affixed to a box. The mailing label identifies petitioner as the addressee and respondent’s office in Little Rock, Arkansas, as the sender. The mailing label is franked, so that no postmark appears on it. Petitioner alleges that he received the box in the mail at or about the end of 1993 and that it contained some, but not all, of his tax records. In this regard, petitioner alleges that when respondent arrested Mr. Amigron in May 1991, see supra C, respondent also seized petitioner’s tax records, which were in Mr. Amigron’s possession, but that respondent subsequently lost some of those records. Petitioner also alleges that when he received the box, “There was a letter inside signed by some lady” explaining how the records had come into respondent’s possession. In responding to the Court’s invitation to produce the letter, petitioner testified that he did not have it. OPINION In general, interest on a deficiency in income tax begins to accrue on the due date of the return for such tax and continues to accrue, compounding daily, until payment is made. See secs. 6601(a), 6622(a). This Court may order an abatement of interest only if there is an abuse of discretion by the Commissioner in failing to abatePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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