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HOWELL v. COMMISSIONER

Dkt. No. 13117-05.

94 T.C.M. 104 (2007)

T.C. Memo. 2007-204

Ralph Howell v. Commissioner.

United States Tax Court.

July 25, 2007.

Attorney(s) appearing for the Case

Nocholas E. Christin, for petitioner.

Timothy Maher, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

Petitioner submitted to the Internal Revenue Service (IRS) a request for abatement of interest relating to his 1984, 1985, and 1986 income tax liabilities. Respondent denied the request. The issue for our determination is whether respondent abused his discretion under section 6404 by failing to abate assessments of interest relating to petitioner's 1984, 1985, and 1986 taxable years.1

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