Banat v. Commissioner
United States Tax Court
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
- Woodral v. CommissionerUnited States Tax Court · 1999
- Lee v. CommissionerUnited States Tax Court · 1999
- Banat v. CommissionerUnited States Tax Court · 1997
- Taylor v. CommissionerUnited States Tax Court · 1999