T.C. Memo. 2002-1
UNITED STATES TAX COURT
MEDA SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16484-99. Filed January 2, 2002.
Neil Deininger, for petitioner.
Ann L. Darnold and Michael J. O’Brien, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge: On April 28, 1999, respondent issued a
notice of final determination denying petitioner’s claim for
abatement of interest. Petitioner timely filed a petition
pursuant to section 6404(i) and Rule 280.1 The issue for
1 Unless otherwise stated, all section references are to the
Internal Revenue Code as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
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