- 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