- 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