Donnie Francis Schroeder - Page 4

                                         -4-                                          
          interest on any amount of unpaid taxes, with interest beginning             
          to accrue on such unpaid taxes as of the last date prescribed for           
          payment.  Sec. 6601(a).5  Petitioner has therefore raised no                
          valid arguments that the determination by Appeals was an abuse of           
          discretion, and we sustain that determination.  All other                   
          arguments by the parties have been considered, and those not                
          discussed herein have been rejected as meritless.  Accordingly,             


                                                  Decision will be entered            
                                             for respondent.                          






















               5 Respondent concedes that interest accrues on related                 
          penalties and additions to tax from Feb. 3, 2003, when respondent           
          assessed petitioner’s 1995 and 1996 deficiencies.                           




Page:  Previous  1  2  3  4  

Last modified: May 25, 2011