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tax liability they agreed to or at least posting a bond or
remitting a deposit. See Chan v. Commissioner, T.C. Memo. 2001-
268. We therefore conclude that the Commissioner did not abuse
his discretion by refusing to abate the interest that the
Nicholses owe.
Summary judgment for the Commissioner being appropriate on
both of the issues before us,
An order and decision in favor
of respondent will be entered.
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