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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