Bourekis v. Comm'r
United States Tax Court
R determined a deficiency for the taxable year 1981. The notice of deficiency did not include any additions to tax or penalties; however, the notice did include a statement that interest would accrue on the deficiency. In a timely petition, Ps attempt to place in dispute penalties and interest.
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R determined a deficiency for the taxable year 1981. The notice of deficiency did not include any additions to tax or penalties; however, the notice did include a statement that interest would accrue on the deficiency. In a timely petition, Ps attempt to place in dispute penalties and interest. Ps did not make a written request with the IRS to abate interest; however, they assert that they made an informal request and that the notice of deficiency should be considered a "final determination" not to abate interest under sec. 6404(g). R filed a motion to dismiss for lack of jurisdiction and to…
1Opinion of the Court
JAMES G. & KATHERINE BOUREKIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bourekis v. Comm'r
Tax Ct. Dkt. No. 5894-97
United States Tax Court
110 T.C. 20; 1998 U.S. Tax Ct. LEXIS 3; 110 T.C. No. 3;
January 13, 1998, Filed
An order will be issued granting respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike With Respect to Penalties and Interest.
R determined a deficiency for the taxable year 1981. The notice of deficiency did not include any additions to tax or penalties; however, the notice did include a statement that interest would accrue on the deficiency. In a…
2Cases cited15 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Monge v. CommissionerUnited States Tax Court · 1989
- United States v. HabigSupreme Court of the United States · 1968
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
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