- 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 abate
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011