- 16 - current tax liability should be consequently adjusted by, inter alia, an abatement of interest pursuant to section 6404(e). With regard to the second question posed by the Court of Appeals--if not, whether petitioner timely received notice from the IRS that his refund had not been applied to his 1987 and 1989 tax deficiencies--we conclude, on the basis of petitioner’s credible evidence, respondent’s admissions, and the lack of credibility of the documentary and testimonial evidence respondent offered--which was contradictory and contained numerous errors--that petitioner did not receive notice from the IRS that his refund had not been applied to his 1987 and 1989 tax deficiencies. With regard to the third question posed by the Court of Appeals--if not, whether petitioner’s current tax liability should be consequently adjusted by, inter alia, an abatement of interest pursuant to section 6404(e)--we conclude, on the basis of petitioner’s credible evidence, respondent’s admissions, and the lack of credibility of the documentary and testimonial evidence respondent offered--which was contradictory and contained numerous errors--that petitioner’s current tax liability should be adjusted by abating the interest for 1989 pursuant to section 6404(e). Since 1992, petitioner has repeatedly asked respondent for a payoff figure so that he could pay the liabilities at issue inPage: 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