Kenneth J. Sigel - Page 3




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               On January 10, 2000, by letter to respondent's Office of the           
          Taxpayer Advocate in Nashville, Tennessee, petitioner again                 
          requested waiver of the $594 addition to tax and abatement of the           
          $5 of interest.                                                             
               By letter dated January 25, 2000, respondent's Nashville               
          Office of the Taxpayer Advocate informed petitioner that his                
          requests for waiver of the addition to tax and for abatement of             
          the interest were denied because it was concluded that                      
          petitioner's $11,000 underpayment of estimated income tax for the           
          last quarter of 1998 was not caused by casualty, disaster, or               
          other unusual circumstances and because it was concluded that               
          imposition of the addition to tax would not be against equity and           
          good conscience.  The letter from respondent also informed                  
          petitioner that he possessed certain “appeal rights”, but the               
          letter did not explain those appeal rights.                                 
               On February 15, 2000, petitioner filed his petition with the           
          Tax Court seeking relief from the above addition to tax and                 
          abatement of the above interest.  At the time the petition was              
          filed, petitioner resided in the Bronx, New York.                           
               As of November 30, 2000, the date of trial, petitioner had             
          not filed a Form 843, Claim for Refund and Request for Abatement            
          of Interest, and respondent had not issued to petitioner a notice           
          of final determination with regard thereto.                                 








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