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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.
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Last modified: May 25, 2011