Jackie H. Hunt - Page 2

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          abatement of interest under section 6404(g).1  We hold that                 
          section 6404(g) does not apply.                                             
          Background                                                                  
               The parties submitted this case fully stipulated.  The                 
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Mason, Texas, at           
          the time she filed her petition.                                            
               On her 1982 Federal income tax return, petitioner claimed a            
          $23,174 loss from Yuma Mesa Jojoba, Ltd. (the partnership).  This           
          Court in Cactus Wren Jojoba, Ltd. v. Commissioner, T.C. Memo.               
          1997-504, filed November 10, 1997, upheld the Commissioner’s                
          determination denying research and experimental deductions of               
          $1,298,031 taken by the partnership for 1982.  On October 13,               
          1998, petitioner’s claimed loss was disallowed in a tax                     
          calculation which was made pursuant to the partnership level                
          proceedings, resulting in a deficiency in her 1982 Federal income           
          tax of $11,587.  On December 18, 1998, respondent issued a                  
          statutory notice of deficiency to petitioner for the taxable year           
          1982, determining additions to tax pursuant to sections                     
          6653(a)(1) and (2), and 6661.  On December 31, 1998, petitioner             
          filed a claim for abatement of the interest with respect to the             
          deficiency determination.  On August 16, 1999, petitioner paid              
          the $11,587 deficiency.                                                     

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code.                                                  




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