- 2 - MEMORANDUM OPINION NIMS, Judge: This matter is before the Court on respondent’s motion for summary judgment (respondent’s motion) pursuant to Rule 121. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. In their amended petition, petitioners seek the Court’s “Review of [respondent’s] Failure to Abate Interest Under Code Section 6404.” The amended petition was filed in response to a letter to petitioners dated January 18, 2005, entitled Full Disclosure - Final Determination, in which petitioners were advised that the final determination of the Internal Revenue Service (IRS) was to deny their request for an abatement of interest. Petitioners resided in Wisconsin when they filed their petition. Background Petitioners are pro se and, from the nature of their filings, are unfamiliar with the procedures of this Court and have had difficulty in applying its Rules. Petitioners’ filings consist of four brief documents: (1) A letter dated January 24, 2005, requesting a petition for review of “Failure to Abate Interest Under Internal Revenue Code Section 6404"; (2) a letter dated February 9, 2005, in which petitioners requested “aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011