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GORGIE v. COMMISSIONER

Docket No. 20572-98.

79 T.C.M. 1628 (2000)

T.C. Memo. 2000-80

Frank J. Gorgie and Rosalia Gorgie v. Commissioner.

United States Tax Court.

Filed March 9, 2000.

Attorney(s) appearing for the Case

Frank J. Gorgie and Rosalie Gorgie, pro sese. Jordan S. Musen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined that petitioners are not entitled to an abatement of interest pursuant to section 6404(e)1 for their 1986, 1987, and 1988 taxable years. Petitioners meet the net worth limitations of section 7430(c)(4)(A)(ii) and timely filed their petition pursuant to section 6404(i) and Rule 280.

The only issue for decision is whether respondent's refusal to...

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