- 10 - failure to pay estimated tax.4 The record does not demonstrate that petitioners raised at the administrative hearing an issue concerning respondent’s failure to abate additions to tax. We do not, therefore, consider any such issue. See Washington v. Commissioner, 120 T.C. 114, 124 (2003). Assuming without prejudice that petitioners did raise such an issue, this Court lacks jurisdiction to review petitioners’ request that we review any such failure. Id. at 124 n.15. Insofar as interest is concerned, the record does not demonstrate that petitioners raised at the administrative hearing an issue concerning respondent’s failure to abate interest. We do not, therefore, consider any such issue. Id. at 123-124. Assuming without prejudice that (1) petitioners did raise such an issue and that (2) we have jurisdiction to consider it, see id. at 123 n.12, we conclude that petitioners have failed to prove that respondent abused his discretion in failing to abate interest. Indeed, petitioners failed to establish any error or delay attributable to one of respondent’s officers’ or employees’ being erroneous or dilatory in performing a ministerial act 4 At trial, petitioners made no effort to show that their failure to timely file or that their failure to timely pay was attributable to reasonable cause and not willful neglect, nor did petitioners make any effort to show that their failure to pay estimated tax was statutorily excused. Similarly, petitioners raised no issue regarding the computation of any of the additions to tax.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011