- 2 - 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 L. 107-134, sec. 112(d)(1)(B), 115 Stat. 2435 (2002). 3 Sec. 6404(i), as cited throughout this opinion, was originally enacted as sec. 6404(g) by the Taxpayer Bill of Rights 2 (TBOR 2), Pub.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011