- 3 -
Petitioners petitioned the Court under section 64041 to review
this abatement disallowance as to all 5 years. We granted
respondent’s motion for partial summary judgment that respondent
does not have authority to abate interest as to 1978. Goettee v.
Commissioner, T.C. Memo. 1997-454. Petitioners have conceded as
to 1983. As a result, only 1979, 1981, and 1982 remain before
the Court in the instant case.
1 The petition refers to sec. 6406, but it is evident that
sec. 6404 is the intended authority.
Unless otherwise indicated, all section, subchapter,
chapter, and subtitle references are to sections, subchapters,
chapters, and subtitles of the Internal Revenue Code of 1954 for
the underpayment years in issue. References to sec. 6404 are to
that section of the Internal Revenue Code of 1986 as in effect
for proceedings commenced at the time the petition in the instant
case was filed.
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