Cynthia A. Bell - Page 10

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                  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                 





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