Donald W. and Kathryn B. Conner - Page 5

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                                     Discussion                                       
               This Court has jurisdiction under section 6330 to review the           
          Commissioner’s administrative determinations.  Sec. 6330(d).                
          Where the validity of the underlying tax liability is not at                
          issue, we review the determination for abuse of discretion.  Sego           
          v. Commissioner, 114 T.C. 604, 610 (2000).  Where the underlying            
          tax liability is in issue, we review de novo.  Goza v.                      
          Commissioner, 114 T.C. 176, 181 (2000).                                     
               Petitioners do not appear to argue that the failure of                 
          respondent to accept the OIC was an abuse of discretion.                    
          Accordingly, we need not, and do not, consider whether the                  
          Appeals officer’s refusal to accept the OIC submitted by                    
          petitioners was arbitrary, capricious, or without sound basis in            
          fact or law.  See Woodral v. Commissioner, 112 T.C. 19, 23                  
          (1999).  We do however consider the question of abatement of                
          interest and additions to tax.                                              
         A.  Abatement of Interest                                                    
               We have jurisdiction over petitioners’ request for abatement           
          of interest because the Court has jurisdiction to review the                
          Commissioner’s refusal to rebate interest under section 6404.               
          Katz v. Commissioner, 115 T.C. 329, 340-341 (2000); Moore v.                
          Commissioner, 114 T.C. 171, 175 (2000).  This Court may order an            
          abatement of interest if the Commissioner abuses his discretion             
          in failing to abate interest.  Sec. 6404(h)(1).  The taxpayer               






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