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petitioners’ case. On October 28, 1998, Manager Laverty
conferred telephonically with petitioners concerning their audit.
The Commissioner’s discretionary power to abate interest is
conditioned upon a finding that the error or delay is not
“significantly” attributable to the taxpayer. Sec. 6404(e)(1).
Respondent requested documentation supporting petitioners’ claim
to the NOL, and petitioners failed to provide such documentation.
Any delay with respect to the resolution of petitioners’ case
during this second period was “significantly” attributable to
petitioners.
Petitioners have not demonstrated that respondent abused his
discretion in refusing to abate interest during either of the
periods at issue.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011