- 2 -
to section 6404(i) and Rule 280.1 The sole issue for decision is
whether respondent abused his discretion in denying petitioner’s
request for abatement of interest.
Background
The parties have stipulated some of the facts, which we
incorporate in our findings by this reference. Petitioner is a
Kentucky corporation. When the petition was filed, petitioner’s
principal place of business was in South Shore, Kentucky.
On its 1995 Form 1120, U.S. Corporation Income Tax Return,
petitioner claimed a $188,660 depreciation deduction with respect
to certain used cars that were part of its car-rental program
(the used cars). In calculating this depreciation deduction,
petitioner assigned the used cars zero salvage value.
On June 18, 1997, respondent’s revenue agent first contacted
petitioner concerning its 1995 Federal income tax return. On
July 14, 1998, the revenue agent issued her report, proposing
that petitioner’s claimed depreciation deduction should be
reduced by $166,358, based on her conclusion that the salvage
value of the used cars was 89 percent of original cost.
On February 16, 1999, respondent granted petitioner’s
request for an Appeals conference. On or about January 10, 2000,
petitioner and the Appeals officer reached a settlement, agreeing
1 Unless otherwise stated, all 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 Next
Last modified: May 25, 2011