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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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