- 6 - deficiencies from the time they were due until they were paid. Petitioner seeks review of respondent’s refusal to abate interest.4 Discussion Petitioner argues that the interest on the reduced deficiencies should be abated because respondent wrongfully refused to postpone and transfer the initial audit to May 1995 in California, and because respondent is responsible for all delays after May 1995 in reconsidering the assessment. Petitioner also objects in his responses to respondent’s motion for summary judgment, contending that summary judgment is an unfair procedure because it is “not a mechanism for presenting my case and on top of that it is not a forum I ever agreed to.” Petitioner wants a trial so that he can call or force respondent to call as witnesses various Internal Revenue Service employees with whom he had contact both in Pennsylvania and California, and can compel respondent to produce a “short list” of 20 categories of documents, including personal records of respondent’s auditors, respondent’s auditor and employee hiring guidelines and training programs, the results of all customer satisfaction 4The parties have not made clear what is the amount in dispute. It appears to us that the total amount in dispute is less than $1,000, consisting of interest on the agreed deficiencies of approximately $1,600 from, at the earliest, May 1995 (when petitioner first wanted the audit to be held) until petitioner paid the deficiencies in 2000.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011