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tax liability and nevertheless was unable to pay the tax or would
have suffered undue hardship if he had paid it on the due date.
Id.
On several occasions petitioner asserted he has very
limited financial resources, but he has failed to provide
financial evidence every time he has been asked to substantiate
these statements. Petitioner is unable to show his failure to
pay was due to reasonable cause. The Court concludes petitioner
is liable for the addition to tax under section 6651(a)(2) for
failure to make timely payment of income tax for the years at
issue.
Petitioner asserts the payment of interest should be abated
because it accumulated to his detriment due to respondent’s
delays and payment will cause an undue hardship because of his
limited financial resources.
We apply an abuse of discretion standard when reviewing the
Commissioner's failure to abate interest. Krugman v.
Commissioner, 112 T.C. 230, 239 (1999). Section 6404(e) permits
the Commissioner to abate interest with respect to an error or
delay in payment of tax resulting from an employee of the
Internal Revenue Service’s being erroneous or dilatory in
performing a ministerial act. There is no provision under
section 6404 or the regulations promulgated thereunder that
allows for the abatement of interest due to financial hardship.
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