James Edward Crawford - Page 2




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          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  The Court agrees with and adopts the opinion of the             
          Special Trial Judge which is set forth below.                               
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PANUTHOS, Chief Special Trial Judge:  On April 7, 2000,                
          respondent issued a notice of final determination denying                   
          petitioner’s claim to abate interest for tax year 1980.                     
          Petitioner challenged the determination by timely filing a                  
          petition under section 6404(i) and Rule 281.                                
               The issue for decision is whether respondent abused his                
          discretion in denying petitioner's request for abatement of                 
          interest assessed from July 1993, through the present date with             
          respect to petitioner’s 1980 taxable year.                                  
                                  FINDINGS OF FACT                                    
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioner resided in Brandon,           
          Florida, at the time his petition was filed with the Court.                 
               In 1983, petitioner invested in the First Energy Leasing tax           
          shelter (First Energy) and claimed an investment tax credit of              
          $10,000, of which he applied $3,670 to his 1983 tax liability.              
          He carried back $6,330 of the credit to his 1980 tax year for               
          which he filed a Form 1045, Application for Tentative Refund,               
          received by the Cincinnati Service Center on March 20, 1984.                








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