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only issue for decision is whether respondent abused his
discretion in failing to abate the assessment of interest for the
periods April 15, 1997, to and including April 16, 1998, and May
1, 1999, until paid.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. On the date the petition
was filed, petitioner resided in Melrose Park, Illinois.
During 1996, petitioner received a $177,412 distribution
from a deceased friend’s individual retirement account (IRA). No
Federal income tax was withheld from the distribution.
Petitioner sought advice from several sources to determine
whether she had to pay Federal income tax on the distribution
from the IRA. A financial adviser at a bank incorrectly advised
her that if she rolled the entire distribution over, she could
avoid income tax. Internal Revenue Service personnel, answering
a telephone call from petitioner, told her the advice she had
received from the financial adviser was correct.
Petitioner had a 1996 Federal income tax return prepared at
a senior citizen’s center reporting no income tax due. She had
the tax return checked for accuracy by H & R Block but did not
file it. On April 2, 1998, petitioner took the tax return to the
Internal Revenue Service’s Downers Grove, Illinois, office, where
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