- 2 - Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE DEAN, Special Trial Judge: On July 31, 2000, respondent issued a notice of final determination denying petitioner's claim for the abatement of interest for tax years 1990 and 1991. Petitioner challenged the determination by timely filing a petition under section 6404(i), as in effect at the time the petition was filed, and Rule 281. The issue for decision is whether respondent abused his discretion by failing to abate assessments of interest relating to petitioner's 1990 and 1991 tax years. Background The stipulation of facts and the accompanying exhibits are incorporated herein by reference. Petitioner resided in Hutchins, Texas, at the time his petition was filed with the Court. Petitioner's 1990 and 1991 Federal income tax returns were subjected to examination by the Internal Revenue Service (IRS) beginning on February 2, 1993. His first meeting with the revenue agent assigned to perform the examination took place on March 1, 1993. The revenue agent referred petitioner's case to the Criminal Investigation Division (CID) of IRS on November 2,Page: Previous 1 2 3 4 5 6 7 8 Next
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