Law Offices of Michael B. L. Hepps - Page 13

                                       - 13 -                                         
          However, because respondent did not adequately consider section             
          6404(a) in making his final determination that petitioner was not           
          entitled to an abatement of interest under section 6404 and                 
          because there is a dispute regarding the material facts, we are             
          unable to conclude that respondent is entitled to summary                   
          judgment with respect to section 6404(a).  See H & H Trim &                 
          Upholstery Co. v. Commissioner, T.C. Memo. 2003-9.                          
               To reflect the foregoing,                                              
                                             An appropriate order                     
                                        will be issued.                               





























Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  

Last modified: May 25, 2011