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and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: On August 14, 2000,
respondent issued a notice of final determination denying
petitioner’s claim under section 6404(e) for abatement of
interest related to petitioner’s 1982 through 1987 taxable years.
Petitioner timely filed a petition with this Court under section
6404(i)2 and Rules 280 through 2843 to review respondent’s
determination.
Shortly before the scheduled trial date, respondent filed a
motion under Rule 120(a) for judgment on the pleadings. The
motion was taken under consideration, and the trial proceeded on
the merits.
The only issue for decision is whether respondent abused his
discretion in denying petitioner’s request to abate interest
1(...continued)
filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 Sec. 6404(i) was redesignated sec. 6404(h) by the Victims
of Terrorism Tax Relief Act of 2001, Pub. L. 107-134, sec.
112(d)(1)(B), 115 Stat. 2435 (2002).
3 Sec. 6404(i), as cited throughout this opinion, was
originally enacted as sec. 6404(g) by the Taxpayer Bill of Rights
2 (TBOR 2), Pub. L. 104-168, sec. 302, 110 Stat. 1457 (1996).
Sec. 6404(g) was redesignated sec. 6404(i) by the Internal
Revenue Service Restructuring & Reform Act of 1998, Pub. L. 105-
206, secs. 3305(a), 3309(a), 112 Stat. 743, 745.
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