Legal Opinion

Banat v. Commissioner

United States Tax Court

Decided April 14, 2000No. 2237-97Unpublished

P filed a petition for a determination that R's failure to abate interest under sec. 6404(e), I.R.C., with respect to petitioner's 1985, 1986, and 1987 taxable years was an abuse of discretion and for an abatement order. HELD: P has not established any erroneous or dilatory ministerial acts by R giving rise to the assessment of interest after P was first contacted in writing about the deficiency and before interest was assessed.

1Opinion of the Court

ROBERT BANAT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Banat v. Commissioner

No. 2237-97

United States Tax Court

T.C. Memo 2000-141; 2000 Tax Ct. Memo LEXIS 170; 79 T.C.M. (CCH) 1941;

April 14, 2000, Filed

Decision will be entered for respondent.

P filed a petition for a determination that R's failure to

abate interest under sec. 6404(e), I.R.C., with respect to

petitioner's 1985, 1986, and 1987 taxable years was an abuse of

discretion and for an abatement order.

HELD: P has not established any erroneous or dilatory

ministerial acts by R giving rise to the assessment of interest

after P…

2Cases cited4 opinions

  1. Woodral v. CommissionerUnited States Tax Court · 1999
  2. Lee v. CommissionerUnited States Tax Court · 1999
  3. Banat v. CommissionerUnited States Tax Court · 1997
  4. Taylor v. CommissionerUnited States Tax Court · 1999

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