Lee v. Commissioner
United States Tax Court
P and his former wife claimed losses from a tax shelter partnership on their 1980 Federal income tax return. In April 1984, R issued a notice of deficiency denying those losses. In July 1984, P filed a petition in this Court contesting the denial of the losses. P's case was not resolved until 1995 when P and R entered a settlement agreement.
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P and his former wife claimed losses from a tax shelter partnership on their 1980 Federal income tax return. In April 1984, R issued a notice of deficiency denying those losses. In July 1984, P filed a petition in this Court contesting the denial of the losses. P's case was not resolved until 1995 when P and R entered a settlement agreement. Pursuant to the settlement agreement, the Court entered a decision that there was a deficiency in P's Federal income tax for 1980. In 1995, R granted P's former wife innocent spouse relief pursuant to sec. 6013(e), I.R.C. Pursuant to sec. 6404(e), I.R.C.,…
1Opinion of the Court
Vasquez, Judge:
On November 5, 1996, respondent issued a notice of final determination denying petitioner’s claim to abate interest pursuant to section 6404(e).1
The sole issue for decision is whether petitioner is entitled to an abatement of interest pursuant to section 6404(e).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference.
At the time the petition was filed, petitioner resided in Benicia, California, and his net worth did not exceed $2 million. Petitioner has a college degree…
2Cases cited2 opinions
- United States v. KordelSupreme Court of the United States · 1970
- Woodral v. CommissionerUnited States Tax Court · 1999
3Cited by50 opinions
- Katz v. CommissionerUnited States Tax Court · 2000
- Corson v. Comm'rUnited States Tax Court · 2004
- Taylor v. CommissionerUnited States Tax Court · 1999
- Beagles v. Comm'rUnited States Tax Court · 2003
- Allcorn v. CommissionerUnited States Tax Court · 2012
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