- 2 - OPINION OF THE SPECIAL TRIAL JUDGE CARLUZZO, Special Trial Judge: On September 16, 1998, respondent issued a notice of final determination denying petitioners' request to abate interest on income tax deficiencies for the years 1989 and 1990. In response to the notice, petitioners filed a timely petition pursuant to section 6404(i). The issue for decision is whether respondent’s failure to abate interest assessed on petitioners’ 1989 and 1990 income tax deficiencies was an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioners are husband and wife. At the time the petition was filed, petitioners resided in Lucedale, Mississippi, and their net worth did not exceed $2 million. References to petitioner are to Larry D. Scott. Petitioner is and was during all relevant times the sole proprietor of a general contracting business (the business). A portion of petitioners’ residence was used as an office in connection with the business. During 1989 and 1990, the income petitioner earned and the expenses he incurred in connection with the business were reported on Schedules C, Profit or Loss From Business (Sole Proprietorship), included with the joint Federal income tax returns timely filed by petitioners for those years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011