T.C. Memo. 2002-312
UNITED STATES TAX COURT
RAYMOND WRIGHT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6240-01L. Filed December 26, 2002.
P failed to file returns for 1987 and 1989. P
received a notice of deficiency for 1987 and 1989. P
petitioned the Court. The Court ruled for R, and P
appealed. The Court of Appeals affirmed our decision.
R sent a Notice of Intent to Levy and Notice of
Your Right to a Hearing to P for 1987 and 1989. P
requested a sec. 6330, I.R.C., hearing. R held a sec.
6330, I.R.C., hearing with P. R determined that R
could proceed with the proposed levy action.
Held: P raised the issue of interest abatement at
the sec. 6330, I.R.C., hearing. Therefore we have
jurisdiction over this issue. Katz v. Commissioner,
115 T.C. 329 (2000).
Held, further, P is not entitled to interest
abatement for amounts greater than those abated or
conceded by R because P failed to file returns for 1987
and 1989 and failed to pay in full the amount of tax he
owed for those years.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011