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Joe Nathan Wright and Lola H. Wright, pro sese.
Alvin A. Ohm, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: This case is before the Court for review of
respondent’s failure to abate interest. Unless otherwise noted,
all section references are to the Internal Revenue Code of 1986,
as amended.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference. At the time they filed the petition, petitioners
resided in Richardson, Texas.
Petitioners’ 1993 and 1994 Federal Income Tax Returns
Petitioners timely filed Federal income tax returns for
their 1993 and 1994 taxable (calendar) years (the 1993 return and
the 1994 return, respectively). On the 1993 return, petitioners
reported tax of $66,451 and prior payments of $2,000.
Petitioners made an additional $2,000 payment when they filed the
1993 return. On the 1994 return, petitioners reported tax of
$60,325 and prior payments of $2,000. Petitioners made an
additional $1,000 payment when they filed the 1994 return.
Petitioners’ Offers in Compromise
On or before September 18, 1995, respondent received an
offer in compromise from petitioners dated August 30, 1995,
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