Legal Opinion

Momot v. Comm'r

United States Tax Court

Decided September 26, 2006No. 2506-05Unpublished

Ps requested R to abate assessments of interest on deficiencies arising from Ps' investment in a tax shelter partnership. R issued a notice of final determination denying Ps' abatement claim. Ps filed a petition for review of R's failure to abate interest. Held: R's failure to abate interest was not an abuse of discretion under sec. 6404(e)(1), I.R.C.

1Opinion of the Court

JOSEPH AND THERESA MOMOT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Momot v. Comm'r

No. 2506-05

United States Tax Court

T.C. Memo 2006-207; 2006 Tax Ct. Memo LEXIS 211; 92 T.C.M. (CCH) 303; RIA TM 56633;

September 26, 2006, Filed

Ps requested R to abate assessments of interest on deficiencies

arising from Ps' investment in a tax shelter partnership. R

issued a notice of final determination denying Ps' abatement

claim. Ps filed a petition for review of R's failure to abate

interest.

Held: R's failure to abate interest was not an abuse of

discretion under sec. 6404(e)(1), I.R.C.

Joseph and…

2Cases cited6 opinions

  1. Woodral v. CommissionerUnited States Tax Court · 1999
  2. Fargo v. Comm'rUnited States Tax Court · 2004
  3. Lee v. CommissionerUnited States Tax Court · 1999
  4. Beagles v. Comm'rUnited States Tax Court · 2003
  5. Bergford v. CommissionerCourt of Appeals for the Ninth Circuit · 1993

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