124 T.C. No. 17
UNITED STATES TAX COURT
JOHN G. GOETTEE, JR. AND MARIAN GOETTEE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 26591-96. Filed May 31, 2005.
Ps claimed investment credits and losses arising out of
a partnership in which they held a limited interest. By
notice of deficiency, R disallowed these claimed credits and
losses. Ps accepted a settlement offer from R and paid all
deficiencies and additions reflected in the entered
decision. Ps requested abatement of interest on these
amounts. R initially disallowed the abatement request in
full, then later allowed partial abatement. Ps then paid
the remaining assessed interest liabilities. Ps petitioned
this Court to review R’s disallowance of interest
abatements. After R’s concessions, we determined (1) R
abused R’s discretion only for the period Jan. 24 through
Apr. 24, 1995, and not for any of the other time periods
(aggregating about 15-3/4 months) specifically put in issue,
* This opinion supplements our previously filed opinions in
Goettee v. Commissioner, T.C. Memo. 1997-454, T.C. Memo. 2003-43
(hereinafter sometimes referred to as Goettee I), and T.C. Memo.
2004-9.
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