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Court any petition for redetermination in respect of the notice
of deficiency for 1984 and 1985.
In October 1988, the Court entered a stipulated decision in
docket No. 43255-85 pursuant to the parties’ agreement. The
decision reflects petitioner’s liability for deficiencies in
income taxes and additions to tax for 1982 and 1983.
Over the next several years, petitioner attempted to resolve
his tax liabilities for 1984 and 1985. During this period,
petitioner also requested that respondent abate penalties and
interest for 1982, 1983, 1984, and 1985.
By letter dated March 19, 1998, respondent advised
petitioner that because of the Court’s decision in docket No.
43255-85, respondent would not abate penalties or interest for
1982 or 1983. However, respondent advised petitioner that
respondent would abate: (1) Assessments of penalties and interest
for 1984 (resulting in a credit balance for that year of
$5,451.13); and (2) assessments of tax, penalties, and interest
for 1985 (resulting in a credit balance for that year of
$6,378.08).
On September 13, 2000, respondent issued to petitioner a
notice of final determination under section 6404 disallowing his
claim for abatement of interest for 1982 and 1983. Petitioner
then filed with the Court a timely petition for review, assigned
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