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B. The Taxable Year 1994
On or about August 9, 1996, petitioner was notified of the
examination of her 1994 income tax return. Notification of the
examination apparently prompted petitioner to make an advance
payment of $500, which was posted to petitioner’s account on
September 19, 1996. Shortly thereafter, by an examination report
dated October 1, 1996, respondent proposed a deficiency in
petitioner’s income tax of $3,966, to which petitioner agreed.
On October 28, 1996, respondent assessed the deficiency and
interest thereon.
In our view, the record does not reveal any ministerial
error or delay by respondent. Accordingly, we hold that
respondent did not abuse his discretion in refusing to abate
interest for the period from August 9, 1996, to April 3, 1997,
the date on which petitioner’s account was fully paid.
C. The Taxable Year 1995
In or about October 1996, petitioner was notified in writing
of the examination of her 1995 income tax return through the
receipt of an examination report dated October 4, 1996.
Thereafter, on December 23, 1996, respondent sent petitioner a
notice of deficiency, which was substantively identical to the
examination report.12 Petitioner did not timely file a petition
12 In contrast to the sending of the notice of deficiency
for 1993, there is nothing in the record to suggest that
respondent erred in sending petitioner a notice of deficiency for
(continued...)
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