- 2 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011