Christine A. Dormer - Page 1

                                 T.C. Memo. 2004-167                                  

                               UNITED STATES TAX COURT                                

                         CHRISTINE A. DORMER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10231-03.            Filed July 14, 2004.                   

                    During June of 2002, P and R executed a Form                      
               12257, Summary Notice of Determination, Waiver of Right                
               to Judicial Review of a Collection Due Process                         
               Determination, and Waiver of Suspension of Levy Action,                
               with respect to P’s 1998 taxable year.  The document                   
               specified that P’s tax liability would be decreased by                 
               a certain amount and that an accuracy-related penalty                  
               would be abated in full.  P paid the remaining income                  
               tax liability, and R later issued to P a notice of                     
               balance due pertaining to interest and an addition to                  
               tax owing for 1998.                                                    
                    Held:  R’s failure to abate interest for 1998 was                 
               not an abuse of discretion.                                            

               Sudhir R. Patel, for petitioner.                                       
               James Brian Urie, for respondent.                                      

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