Raymond Wright - Page 16

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          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 in              






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