David and Monika Zisskind - Page 2

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          petitioners seek review of respondent’s determination.  The                 
          issues for decision are:  (1) Whether petitioners are liable for            
          an addition to tax under section 6651(a)(2); (2) whether                    
          respondent abused his discretion by determining that petitioners            
          were not entitled to an abatement of interest under section                 
          6404(e); and (3) whether respondent abused his discretion by                
          determining that a Federal tax lien was appropriately filed and             
          would remain in effect until petitioners’ tax liability was                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the supplemental stipulation of facts,            
          and the attached exhibits are incorporated herein by this                   
          reference.  At the time the petition was filed, petitioners                 
          resided in South Boston, Massachusetts.                                     
               During 1999, David Zisskind (petitioner) was a self-employed           
          real estate developer and contractor.  Petitioner owned an                  
          interest in Mercer Properties, L.L.C. (Mercer).  In April 1999,             
          Mercer sold real property developed by petitioner.  In April or             
          May 1999, Mercer distributed profits of $156,857 from that sale             
          to petitioner.  Petitioner knew that he would owe tax as a result           

          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.  Amounts              
          are rounded to the nearest dollar.                                          

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