- 4 - pursuant to section 6404(e); and (d) in any case, whether the current interest abatement that petitioner had already received was correct in the light of (1) the IRS’s failure to give petitioner the appropriate withholding credits for 1987 and 1989, and (2) his June 21, 1994, payment of $6,681.22. On October 19, 2004, the Court ordered the parties to file, on or before November 2, 2004, written status reports in which the parties were to advise the Court of their positions regarding the appropriate means for this Court to implement the mandate of the Court of Appeals. On November 2, 2004, respondent filed his status report, and on November 5, 2004, petitioner filed his status report (with a service date of November 2, 2004). In his November 2004 status report, respondent stated that he was awaiting detailed transcripts of petitioner’s tax accounts to address the four issues as outlined in the mandate of the Court of Appeals. On February 2, 2005, the Court again ordered the parties to file, on or before February 16, 2005, written status reports in which the parties were to advise the Court of their positions regarding the appropriate means for this Court to implement the mandate of the Court of Appeals. On February 15, 2005, respondent filed his status report, and on February 18, 2005, petitioner filed his status report (with a service date of February 16, 2005).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011