T.C. Memo. 2004-121
UNITED STATES TAX COURT
THOMAS FREDERICK DADIAN AND LOIS ANN DADIAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1051-02. Filed May 19, 2004.
Thomas Frederick and Lois Ann Dadian, pro sese.
Jonathan H. Sloat, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: Respondent denied petitioners’ request under
section 64041 for abatement of interest on their Federal income
tax deficiency for 1984. The issue for decision is whether
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time the petition was
filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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