- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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