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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,
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