T.C. Memo. 2004-69
UNITED STATES TAX COURT
JOE NATHAN WRIGHT and LOLA H. WRIGHT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8200-02. Filed March 18, 2004.
Ps submitted multiple offers in compromise with
respect to their reported but unpaid Federal income tax
liabilities for 1993 and 1994. R did not accept any of
Ps’ offers. Ps requested abatement of interest under
sec. 6404(e), I.R.C., on the ground that R unreasonably
delayed the processing of their offers in compromise.
R rejected Ps’ request for interest abatement.
Held: Ps have failed to establish that any delay
in their payment of their 1993 and 1994 tax liabilities
is attributable to any action or inaction on the part
of IRS personnel in processing Ps’ offers in
compromise; therefore, interest is not abatable under
sec. 6404(e), I.R.C., and R did not abuse his
discretion in rejecting Ps’ request for abatement.
Page: 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011