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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.
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