Thomas Corson - Page 5

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          taxable years other than 1981, Appeals Officer Sivick stated:               
          “Your desire and belief are not the relevant factors considered             
          under the law in abatement of interest cases.  Therefore, I would           
          not consider this argument to have any merit for purposes of a              
          request for abatement of interest.”  Appeals Officer Sivick did             
          not address the content or effect of the settlement agreements.             
          In closing, Appeals Officer Sivick gave petitioner until October            
          17, 2001, to continue to present arguments.                                 
               In a notice of final determination dated July 26, 2002,                
          respondent denied petitioner’s request for an abatement of                  
          interest.  Respondent explained the denial of petitioner’s                  
          request as follows:  “We did not find any errors or delays on our           
          part that merit the abatement of interest in our review of                  
          available records and other information for the period from April           
          15, 1984 to October 9, 1995.”                                               
               On January 21, 2003, petitioner filed a petition with this             
          Court pursuant to section 6404(h) and Rule 280 seeking review of            
          respondent’s refusal to abate interest under section 6404(e).  In           
          his petition, petitioner primarily contended that, pursuant to              
          section 6231(b)(1)(C), when the parties executed the settlement             
          agreements, partnership items converted to nonpartnership items;            
          the conversion to nonpartnership items triggered the 1-year                 
          statutory limitations period on assessment contained in section             
          6229(f) (section 6229(f) assessment period); respondent failed to           






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