Larry G. Schuster - Page 8




                                        - 8 -                                         
          applied the proceeds of the second levy to petitioner’s                     
          undisputed tax liabilities for subsequent tax years.  Petitioner            
          was not assessed any additional interest for 1993.                          
               Respondent chose not to abate interest because petitioner’s            
          1993 tax liability was resolved by the first levy, and the                  
          proceeds from the second levy were applied to petitioner’s                  
          outstanding tax liabilities for subsequent years.  Respondent’s             
          decision not to abate interest was not arbitrary, capricious, or            
          without sound basis in fact or law.  Accordingly, we hold that              
          respondent’s denial of petitioner’s claim to abate interest was             
          not an abuse of discretion.                                                 

                                             Decision will be entered for             
                                        respondent.                                   
                                                                                     
























Page:  Previous  1  2  3  4  5  6  7  8  

Last modified: May 25, 2011