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
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