Robert Wish and Erin Wish Riehs - Page 1

                                 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.                

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