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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
satisfied.
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
1(...continued)
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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