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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.
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