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1986 4-15-1987 3-26-2001 34,547.54
1987 4-15-1988 3-26-2001 14.91
As a result of petitioner’s making a deposit in the nature of a
cash bond in the amount of $197,000 on March 26, 2001, respondent
stopped interest from accruing on that date.
G. Petitioner’s Interest Abatement Claim
On June 3, 1998, petitioner initiated correspondence with
respondent requesting an explanation for respondent’s imposing
interest relating to a tax-motivated transaction pursuant to
section 6621(c). More specifically, petitioner wanted respondent
to provide his basis for determining that petitioner’s investment
in SGE was a tax-motivated transaction. Respondent treated this
letter as an informal claim for interest abatement.
On June 22, 1998, respondent denied petitioner’s informal
claim for abatement of interest for the 1982 through 1987 tax
years. Respondent stated that tax-motivated interest was
applicable on account of the abusive nature of the SGE
partnership. In addition, respondent determined that there was
no delay or error relating to the performance of a ministerial
act warranting abatement of interest. The correspondence from
respondent informed petitioner that he could request
reconsideration of respondent’s findings with the IRS Appeals
Office.
On July 22, 1998, petitioner appealed respondent’s denial of
the informal interest abatement claim. Specifically, petitioner
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