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with respect to the Brauns’2 joint Federal income tax returns for
1994 and 1997. The sole issue for decision is whether respondent
abused his discretion in failing to abate interest. We hold that
respondent did not abuse his discretion.
FINDINGS OF FACT
The parties have stipulated some of the facts, which are
incorporated in our findings by this reference. Petitioner
resided in Grandview, Missouri, when he filed the petition.
The Brauns’ 1994 and 1997 Income Tax Returns
Petitioner and his wife had consistently filed their income
tax returns and paid their income tax liabilities timely until
1994, when a series of events caused the Brauns to file returns
and pay their income tax liabilities late. These events began
when petitioner lost his job in 1994. Shortly thereafter,
petitioner was shot through the throat, lung, and shoulder by an
intruder burglarizing his home in early 1995. Petitioner
survived, but the effect on his employability and finances was
devastating. After spending 8 days on life support, petitioner
spent another 17 days in the hospital and approximately 7 more
months bedridden, undergoing surgeries, and receiving extensive
therapy.
2The Brauns are petitioner and his wife, Tammy J. Braun, who
filed joint Federal income tax returns. Because petitioner filed
the petition is his name only, we refer to the Brauns when
describing their joint tax liabilities and actions they took
together. References to petitioner are to petitioner
individually.
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