- 2 - OPINION OF THE SPECIAL TRIAL JUDGE CARLUZZO, Special Trial Judge: On February 28, 2001, respondent issued a notice of final determination denying in part petitioners’ request to abate interest on their 1989 Federal income tax liability. In response to that notice, petitioners timely petitioned this Court for a review of respondent’s denial. Our jurisdiction is established by section 6404(h).2 The issue for decision is whether respondent’s failure to abate interest on petitioners’ 1989 Federal income tax liability is an abuse of discretion. Background Petitioners resided in Barrow, Alaska, at the time the petition was filed. The facts in this case, all of which have been stipulated, are easily summarized. Petitioners are husband and wife. They filed a timely joint 1989 Federal income tax return.3 Computational errors were made on the return, and as a result the total tax liability reported on the return was understated. A notice was sent to petitioners 2 Sec. 6404(h) was previously designated sec. 6404(i). See Victims of Terrorism Tax Relief Act of 2001, Pub. L. 107-134, sec. 112(d)(1)(B), 115 Stat. 2435. 3 The return has not been included in the record. Details of the return are set forth in a document prepared by respondent’s Appeals officer in response to petitioners’ administrative claim for interest abatement. The parties stipulated the truth of the factual portions of this document.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011