Yeomans v. Comm'r
United States Tax Court
P was liable for a Federal income tax deficiency for his 1982 tax year and paid that deficiency on Mar. 13, 2007. He requested an abatement of all interest that accrued on the deficiency from Apr. 15, 1983, to Dec. 1, 2006. R determined that P was not entitled to interest abatement.
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P was liable for a Federal income tax deficiency for his 1982 tax year and paid that deficiency on Mar. 13, 2007. He requested an abatement of all interest that accrued on the deficiency from Apr. 15, 1983, to Dec. 1, 2006. R determined that P was not entitled to interest abatement. R now concedes that P is entitled to interest abatement for the period from Apr. 13, 2005, to Mar. 13, 2007. Held: R's determination that P was not entitled to interest abatement for the period before Apr. 13, 2005, was not an abuse of discretion.
1Opinion of the Court
RALPH D. YEOMANS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Yeomans v. Comm'r
No. 14635-07
United States Tax Court
T.C. Memo 2009-216; 2009 Tax Ct. Memo LEXIS 219; 98 T.C.M. (CCH) 57942;
September 17, 2009, Filed
P was liable for a Federal income tax deficiency for his 1982 tax year and paid that deficiency on Mar. 13, 2007. He requested an abatement of all interest that accrued on the deficiency from Apr. 15, 1983, to Dec. 1, 2006. R determined that P was not entitled to interest abatement. R now concedes that P is entitled to interest abatement for the period from Apr. 13, 2005,…
2Cases cited10 opinions
- Woodral v. CommissionerUnited States Tax Court · 1999
- Hinck v. United StatesSupreme Court of the United States · 2007
- Lee v. CommissionerUnited States Tax Court · 1999
- Thornock v. Comm'rUnited States Tax Court · 1990
- John J. Waters and Jeanne M. Waters v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992
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