Momot v. Comm'r
United States Tax Court
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
- Woodral v. CommissionerUnited States Tax Court · 1999
- Fargo v. Comm'rUnited States Tax Court · 2004
- Lee v. CommissionerUnited States Tax Court · 1999
- Beagles v. Comm'rUnited States Tax Court · 2003
- Bergford v. CommissionerCourt of Appeals for the Ninth Circuit · 1993
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