Richard Nichols and Lisa Nichols - Page 15

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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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