Robert B. Kemp, Jr. - Page 2

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          pursuant to section 6404(h).1  The issue for decision is whether            
          respondent abused his discretion in failing to abate interest on            
          petitioner’s Federal income tax liabilities for 1989 and 1990.              
          We hold that he did not.                                                    
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  The stipulation of facts and the attached exhibits are           
          incorporated herein by this reference.  At the time of filing of            
          the petition, petitioner resided in Hixson, Tennessee.                      
               In June 1994, petitioner was informed by letter that his               
          1992 Federal income tax return had been selected for examination.           
          The letter also requested certain documents, including                      
          petitioner’s 1991 and 1993 Federal income tax returns.  Later               
          that month, petitioner had lengthy meetings with the revenue                
          agent who was conducting the examination.  The revenue agent went           
          on maternity leave 2 months later.                                          
               In September 1994, petitioner filed amended Federal income             
          tax returns for 1991, 1992, and 1993, reporting additional                  
          taxable income of $173,817, $191,595, and $63,628, respectively.            

               1 Unless otherwise indicated, all section references are to            
          the applicable provision of the Internal Revenue Code for the               
          periods involved, and all Rule references are to the Tax Court              
          Rules of Practice and Procedure.                                            

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