- 2 - for 1993, 1994, and 1995. Petitioners timely filed a petition seeking review of respondent’s determination not to abate interest. Initially, we must decide whether petitioners reached an enforceable compromise of their tax liabilities under section 7122. We hold that petitioners did not reach an enforceable compromise under section 7122. The remaining issue for decision is whether respondent’s denial of interest abatement with respect to petitioners’ income taxes for 1993, 1994, and 1995 was an abuse of discretion under section 6404.2 For the reasons stated herein, we hold that respondent’s refusal to abate the interest on petitioners’ income tax liabilities from December 22, 1996 to August 11, 1999, was an abuse of discretion but that in all other respects the failure to allow abatement was not an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in Longmont, Colorado, at the time the petition was filed. References to petitioner are to Stanley Harbaugh. 1(...continued) filed, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 Petitioners’ petition requests review only with respect to the interest accrued since August 1996, on their income tax liabilities for 1993, 1994, and 1995.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011