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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.
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Last modified: May 25, 2011