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respondent’s refusal to abate interest constitutes an abuse of
discretion.
Background
The parties’ stipulations are incorporated into this
Memorandum Opinion by reference and, accordingly, are found as
facts in the instant case. At the time he filed his petition,
petitioner resided in Tampa, Florida.
On August 22, 2001, Internal Revenue Service (IRS) Agent
Julie A. Kelley (Agent Kelley) initiated examination of
petitioner’s 1999 return. On September 10, 2001, Agent Kelley
initiated examination of petitioner’s 1998 return. On
September 25, 2001, Agent Kelley worked on notices of proposed
adjustments to items reported on petitioner’s income tax returns
for 1998 and 1999.
On September 27, 2001, Agent Kelley sent petitioner a letter
requesting an extension of the limitations period for assessing
petitioner’s taxes for 1998. Agent Kelley drew up a Revenue
Agent Report on October 2, 2001. Petitioner discussed the
Revenue Agent Report with Agent Kelley on October 5, 2001.
Subsequently, petitioner discussed the Revenue Agent Report with
his representative, Laymond Cloud (Mr. Cloud), and informed Agent
Kelley on October 22, 2001, that he would not agree to sign a
report until adjustments to all of his returns under audit were
consolidated into one report. On October 24, 2001, Agent Kelley
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Last modified: March 27, 2008