- 23 -
forcing respondent to take action to secure the filing of the
returns. Because of petitioner’s lack of cooperation, respondent
eventually resorted to summoning petitioner’s records. As
previously noted, it was not until 1996 that petitioner finally
submitted his delinquent returns for 1987 through 1991. Notably,
petitioner’s accompanying cover letter attributed the late
submission to his health problems rather than to any error or
delay by respondent’s employees; petitioner’s letter thanked the
IRS agents for their “professionalism and patience”.
In sum, petitioner has not shown that respondent abused his
discretion in failing to comply with petitioner’s request for
interest abatement.
We have considered all arguments made by petitioner and have
found those arguments not discussed herein to be moot or without
merit.13
To reflect the foregoing,
Decisions will be entered
for respondent.
13 Although petitioner alleges in his petition that an IRS
agent advised him not to be concerned about interest, which was
“incorrect”, petitioner has not expressly raised this issue at
trial or on brief. We deem petitioner to have abandoned any such
issue. In any event, the record contains no evidence
corroborating this claim.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Last modified: May 25, 2011