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
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