Joseph and Theresa Momot - Page 2

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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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