- 10 -
As in the case of petitioner’s 1998 return, the
certified transcript for tax year 1999 also shows that
statutory notices of balance due were issued to petitioner.
One notice was issued on June 3, 2002, when the balance of
petitioner’s account was $884.66 (i.e., - $81 - $1,868 +
$1,864 + $401.17 + $115.89 + $85 + $367.60). Another
notice was issued to petitioner on July 1, 2002, when the
balance of petitioner’s account was $310.28 (i.e., - $81
- $1,868 + $1,864 + $401.17 + $115.89 + $85 + $367.60 -
$401.17 - $115.89 - $57.32).
The total interest that petitioner paid for 1998 and
1999 is $2,669.97 computed as follows:
7/8/02 Assess interest for 1998 $2,627.36
10/21/02 Abate interest related to additions -420.39
to tax for 1998
3/29/04 Assess additional interest for 1998 129.19
6/3/02 Assess interest for 1999 367.60
7/1/02 Abate interest related to additions-57.32
to tax for 1999
3/29/04 Assess additional interest for 199923.53
2,669.97
Discussion
The purpose of summary judgment is to expedite
litigation and to avoid unnecessary and expensive trials.
See, e.g., Keene v. Commissioner, 121 T.C. 8, 14 (2003);
Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988).
Generally, we grant summary judgment if the pleadings,
answers to interrogatories, depositions, admissions, and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011