T.C. Memo. 2003-106
UNITED STATES TAX COURT
ROBERT L. STEWART, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12947-00. Filed April 17, 2003.
Robert L. Stewart, pro se.
Catherine L. Campbell, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: On June 22, 2000, respondent issued to
petitioner a notice of final determination with respect to
petitioner’s claim to abate interest on his 1990 income tax
deficiency under section 6404(e). In the notice, respondent
partially abated part of the interest and denied the balance of
petitioner’s claim. Petitioner timely filed a petition under
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