Leonard O. Parker, Jr. - Page 14

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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.              
              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                
              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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