Donald B. Hawksley - Page 17




                                       - 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  Next

Last modified: May 25, 2011