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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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