T.C. Memo. 2007-204 UNITED STATES TAX COURT RALPH HOWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13117-05. Filed July 25, 2007. Nicholas E. Christin, for petitioner. Timothy Maher, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: Petitioner submitted to the Internal Revenue Service (IRS) a request for abatement of interest relating to his 1984, 1985, and 1986 income tax liabilities. Respondent denied the request. The issue for our determination is whether respondent abused his discretion under section 6404 byPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007