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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 “a
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Last modified: May 25, 2011