Lawrence S. and Myrna Ahmaogak - Page 2

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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                
          large part petitioners’ request to abate interest on their                  
          Federal income tax liabilities for 1986 through 1989, inclusive,            
          and 1991 (the underlying years).  In response to that notice,               
          petitioners timely petitioned this Court to review 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’ Federal income tax liabilities for the             
          underlying years is an abuse of discretion.                                 
               Petitioners resided in Barrow, Alaska, at the time the                 
          petition was filed.  The facts in this case, all of which have              
          been stipulated, are summarized below.                                      
               Petitioners are husband and wife.  They filed timely joint             
          Federal income tax returns for 1987, 1988, and 1989, but untimely           
          returns for 1986 and 1991.3                                                 

               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 returns have not been included in the record.                   
          Details of the returns 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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