T.C. Memo. 2006-207
UNITED STATES TAX COURT
JOSEPH AND THERESA MOMOT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2506-05. Filed September 26, 2006.
Ps requested R to abate assessments of interest on
deficiencies arising from Ps’ investment in a tax
shelter partnership. R issued a notice of final
determination denying Ps’ abatement claim. Ps filed a
petition for review of R’s failure to abate interest.
Held: R’s failure to abate interest was not an
abuse of discretion under sec. 6404(e)(1), I.R.C.
Joseph and Theresa Momot, pro sese.
George W. Bezold, for respondent.
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