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that determination. On the present record we believe petitioner
has raised an irregularity in the assessment procedure. Under
these circumstances we consider it appropriate to remand this
case for further proceedings as to 1996 concerning the issue of
an abatement of interest and particularly whether petitioner made
a payment of the amount due in accordance with instructions from
respondent’s representative (Ms. Ogle). See Nestor v.
Commissioner, 118 T.C. 162, 167 (2002); see also Rivera v.
Commissioner, T.C. Memo. 2003-35.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An appropriate order
will be issued.
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Last modified: May 25, 2011