T.C. Memo. 2003-217
UNITED STATES TAX COURT
WILLIAM AND PENNY LANDVOGT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12189-02. Filed July 22, 2003.
William Landvogt and Penny Landvogt, pro sese.
James E. Schacht, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: On July 3, 2002, respondent issued a notice
of final determination disallowing petitioners’ claim for
abatement of interest with respect to their 1992, 1993, and 1994
taxable years. Petitioners timely filed a petition under section
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Last modified: May 25, 2011