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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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