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of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
CARLUZZO, Special Trial Judge: In this case, filed pursuant
to section 6404(i),2 petitioner claims that respondent’s failure
to abate interest with respect to her 1990 Federal income tax
liability is an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time that the petition was filed, petitioner resided in
Biloxi, Mississippi, and her net worth did not exceed $2 million.
Petitioner filed a timely 1990 Federal income tax return.
Attached to that return are several Forms W-2, Wage and Tax
Statement, from the following employers in the following amounts:
Employer Amount
Solo Serve Corp. $ 530
Wolf Camera Inc. 1,020
PCA National, Inc. 1,409
Temporaries, Inc. 1,477
Total 4,436
Petitioner also worked as a paralegal for the law firm of
Smith, Currie & Hancock (the law firm) during 1990. At the time
she filed her return, she could not locate any yearend earnings
statements from the law firm, so she estimated those earnings to
2 After the petition was filed in this case, sec. 6404(i)
was redesignated sec. 6404(h) by the Victims of Terrorism Tax
Relief Act of 2001, Pub. L. 107-134, sec. 112(d)(1)(B), (f), 115
Stat. 2434-2435.
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