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6404(i)2 and Rules 280-284. The sole issue for decision is
whether respondent abused his discretion by denying petitioner’s
request to abate interest.
Background
The parties submitted this case fully stipulated. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. Petitioner resided in Great Falls,
Montana, at the time he filed his petition.
Petitioner timely filed his Federal income tax returns for
the years 1992 through 1995. Respondent audited petitioner’s
income tax returns for all these years. Respondent determined
deficiencies in petitioner’s income tax for the years 1992
through 1995.3 Petitioner did not dispute those deficiencies,
and they were assessed. Prior to June 12, 1997, petitioner made
various payments in partial satisfaction of his tax liabilities
for the years 1992, 1993, and 1994. As of July 8, 1997,
petitioner’s outstanding tax liabilities, consisting of
assessments and additional accrued statutory additions, for 1992,
1993, and 1995, were $378.49, $1,124.76, and $128.23,
respectively, for a total of $1,631.48. As of July 7, 1997,
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time that the petition
was filed in this case, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
3Respondent also determined the estimated tax penalty
applied for the taxable year 1995. Petitioner does not dispute
the 1995 estimated tax penalty.
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