- 2 -
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.
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 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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011