T.C. Memo. 2001-23 UNITED STATES TAX COURT SEYMOUR AND BEATRICE LEFFERT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18802-98. Filed January 31, 2001. Seymour Leffert, pro se. Thomas J. Kerrigan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: On September 18, 1998, respondent issued a notice of final determination disallowing petitioners’ claim for abatement of interest relating to petitioners’ 1982 and 1983 taxable years. Petitioners timely filed a petition under section 6404(g)1 and Rule 280.2 The only issue for decision is whether 1Sec. 6404(g) was redesignated sec. 6404(i) by the Internal (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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