T.C. Memo. 2004-125
UNITED STATES TAX COURT
CHARLES DURHAM, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5185-02. Filed May 25, 2004.
Maurice W. Gerard, for petitioner.
Caroline R. Krivacka, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: Section 6404(e) of the Code1 gives the
Commissioner power to abate interest that has accrued on unpaid
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code; Rule references are to the Tax Court
Rules of Practice and Procedure; Constitution references are to
the Constitution of the United States.
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