T.C. Memo. 2004-277
UNITED STATES TAX COURT
LINDA MITCHELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17155-02. Filed December 8, 2004.
Linda Mitchell, pro se.
Michael W. Lloyd, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined that petitioner is not
entitled to abatement of the interest due with respect to her
income tax liability for 1994 pursuant to section 6404(e).1 The
only issue for decision is whether respondent abused his
1 Unless otherwise indicated, section references are to the
Internal Revenue Code, as amended. Amounts are rounded to the
nearest dollar.
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