T.C. Memo. 2001-57 UNITED STATES TAX COURT ROBERT WISH AND ERIN WISH RIEHS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3037-99. Filed March 9, 2001. R examined Ps’ 1981 tax return and issued a notice of deficiency. Anticipating an assessment, Ps posted a cash bond with R. Ps subsequently filed a refund claim for the 1985 tax year, the proceeds of which were to be used to offset any shortfall between the bond and the assessment. R denied the refund claim, and the assessment exceeded the bond. Ps then filed a claim for an abatement of interest for the 1981 tax year. Ps supported their abatement claim with allegations of errors or delays occurring during the processing of their refund claim for 1985. R denied their claim for abatement of interest. Held, the delay in payment of the 1981 outstanding tax liability was not attributable to procedures involved in the processing of the refund claim for 1985 so as to allow relief under sec. 6404(e), I.R.C., 1986.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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