Barry R. Downing and Mary A. Downing - Page 2




                                        - 2 -                                         
                    Held:  We have jurisdiction under sec.                            
               6330(d)(1)(A), I.R.C., to review R’s determination to                  
               proceed with collection of the addition to tax under                   
               sec. 6651(a)(2), I.R.C.                                                
                    Held, further, Ps had no reasonable cause for                     
               failing to pay their 1995 income tax, and thus are                     
               liable for the addition to tax for failure to pay tax                  
               under sec. 6651(a)(2), I.R.C.                                          
                    Held, further, R’s failure to abate interest was                  
               not an abuse of discretion.                                            


               Barry R. Downing and Mary A. Downing, pro se.                          
               Edwina L. Charlemagne, for respondent.                                 


               COLVIN, Judge:  The petition in this case was filed under              
          section 6330(d)1 seeking our review of a determination by                   
          respondent’s Appeals officer that respondent’s proposed                     
          collection action may proceed.  The issues for decision are:                
               1.  Whether we have jurisdiction under section 6330(d)(1)(A)           
          to review respondent’s determination to proceed with collection             
          of the addition to tax under section 6651(a)(2).  We hold that we           
          do.                                                                         
               2.  Whether petitioners had reasonable cause for not paying            
          their 1995 income tax.  We hold that they did not.                          





               1  Section references are to the Internal Revenue Code as              
          amended.                                                                    




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011