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references are to the Tax Court Rules of Practice and 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 14, 2000, respondent
issued a notice of final determination denying petitioners’ claim
to abate interest for tax years 1996 and 1997. Petitioners
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 committed an
abuse of discretion by failing to abate assessments of interest
relating to petitioners’ 1996 and 1997 tax years.
Background
The stipulation of facts and the accompanying exhibits are
incorporated herein by reference. Petitioners resided in
Yardley, Pennsylvania, at the time their petition was filed with
the Court.
Petitioners were issued a notice of deficiency for their
1994 tax year in 1997, and on June 24, 1997, the Court received
and filed a petition for petitioners’ 1994 tax year. The
adjustments made to petitioners’ 1994 income tax return primarily
concerned unreported gambling income and the taxability of the
Social Security income petitioner Harold Kupersmit (Mr.
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