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The sole issue this Court must decide is whether respondent
abused his discretion in denying petitioner’s request for
abatement of interest assessed with respect to petitioner’s 1992
and 1993 taxable years.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Palo Alto, California, at the
time he filed his petition.
For the taxable year 1992, petitioner received wages in the
amount of $14,500 from A. Gordon Enterprises Co., Inc.
Petitioner also received dividend income of $20 in 1992.
For the taxable year 1993, petitioner received wages in the
amount of $26,900 from GTE Corporation. Petitioner also received
dividend income of $22 in 1993.
On February 27, 1995, respondent sent a Proposed Individual
Income Tax Assessment letter (30 day letter) to petitioner at an
address in Lauderhill, Florida (Florida address). This letter
indicated that respondent had no record that petitioner filed a
1992 Federal income tax return and provided a tax calculation
summary.
On May 22, 1995, respondent sent a Proposed Individual
Income Tax Assessment letter (30 day letter) to petitioner at the
Florida address. This letter indicated that respondent had no
record that petitioner filed a 1993 tax return and provided a tax
calculation summary.
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