Robert Wish and Erin Wish Riehs - Page 2




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               Joseph E. Mudd and Linas N. Udrys, for petitioners.                    
               Gary M. Slavett, for respondent.                                       


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  On August 19, 1998, respondent issued a               
          notice of final determination denying petitioners’ request for an           
          abatement of interest under section 6404(e) for their 1981 tax              
          year.1  The issue for decision is whether respondent abused his             
          discretion in failing to abate the assessment of interest.                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioners resided in Laguna Hills, California.                 
          1981 Tax Return                                                             
               During 1981, petitioners invested in a partnership known as            
          Hillcrest Securities.  Respondent examined petitioners’ 1981 tax            
          year, concentrating on petitioners’ tax treatment of their                  
          partnership interest in Hillcrest Securities.  On October 9,                
          1986, respondent issued a notice of deficiency for 1981.                    


               1  References to sec. 6404(e) are to sec. 6404(e) before               
          amendment by sec. 301 of the Taxpayer Bill of Rights 2, Pub. L.             
          104-168, 110 Stat. 1452, 1457 (1996).  Unless otherwise stated,             
          all other section references are to the Internal Revenue Code as            
          amended, and all Rule references are to the Tax Court Rules of              
          Practice and Procedure.                                                     





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