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 betweenPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011