T.C. Memo. 2004-80
UNITED STATES TAX COURT
CHARLES DEVERNA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7870-02. Filed March 22, 2004.
Donald Jay Pols, for petitioner.
Patricia A. Riegger, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: The petition in this case was filed in
response to a notice of determination denying petitioner’s
request to abate interest on income tax liabilities for 1982,
1983, and 1984 pursuant to section 6404(e). The issue for
decision is whether the failure to abate interest between
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