Kersh v. Comm'r
United States Tax Court
P invoked the Court's jurisdiction under sec. 6404(h)(1), I.R.C., to determine whether R abused his discretion by not abating statutory interest. The interest related to Federal income tax deficiencies listed in the decision entered by the Court in P's earlier deficiency proceeding. The interest was not mentioned in the decision.
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P invoked the Court's jurisdiction under sec. 6404(h)(1), I.R.C., to determine whether R abused his discretion by not abating statutory interest. The interest related to Federal income tax deficiencies listed in the decision entered by the Court in P's earlier deficiency proceeding. The interest was not mentioned in the decision. P's sole argument is that she is not liable for the interest under the rationale of Hurt v. United States, 76 AFTR 2d 95-7815 (4th Cir. 1995). There, the Court of Appeals for the Fourth Circuit decided that the taxpayers were not liable for statutory interest because…
1Opinion of the Court
ESTELLE KERSH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kersh v. Comm'r
No. 22731-05
United States Tax Court
T.C. Memo 2009-260; 2009 Tax Ct. Memo LEXIS 264; 98 T.C.M. (CCH) 458;
November 12, 2009, Filed
P invoked the Court's jurisdiction under sec. 6404(h)(1), I.R.C., to determine whether R abused his discretion by not abating statutory interest. The interest related to Federal income tax deficiencies listed in the decision entered by the Court in P's earlier deficiency proceeding. The interest was not mentioned in the decision. P's sole argument is that she is not liable for the…
2Cases cited9 opinions
- Woodral v. CommissionerUnited States Tax Court · 1999
- Hinck v. United StatesSupreme Court of the United States · 2007
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Alphonso Bax and Alice Corrine Bax, Deceased, and Alphonso L. Bax, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Urbano v. Comm'rUnited States Tax Court · 2004
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