- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011