- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007