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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