- 2 -
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: On May 22, 2003, respondent issued a notice
of final determination disallowing petitioner’s claim for
abatement of interest with respect to her 1998 taxable year.
Petitioner timely filed a petition with this Court under section
6404(h) and Rule 280 for review of respondent’s denial.1 The
issue for decision is whether respondent’s failure to abate
interest for the year in issue was an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in Pottsville,
Pennsylvania.
During 1997, petitioner received an offer of employment that
was subsequently revoked. The revocation led to petitioner’s
assertion of various claims against the prospective employer,
which were resolved by means of a settlement agreement dated
1 Unless otherwise indicated, section references are to the
Internal Revenue Code of 1986, as amended, and Rule references
are to the Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011