Stanley R. Harbaugh and Bonnie L. Harbaugh - Page 2

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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                 
                                  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.                                                           

          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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