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JACOBS v. COMMISSIONER

Docket Nos. 18259-98, 1099-99.

79 T.C.M. 1835 (2000)

T.C. Memo. 2000-123

Laurence L. and Patricia Jacobs v. Commissioner. James W. and Janice A. Geis v. Commissioner.

United States Tax Court.

Filed April 10, 2000.

Attorney(s) appearing for the Case

Laurence L. Jacobs, Patricia Jacobs, James W. Geis, and Janice A. Geis, pro sese. Jordan S. Musen and Michael A. Skeen, for the respondent.

MEMORANDUM OPINION

WELLS, Judge:

Respondent determined that petitioners are not entitled to an abatement of interest pursuant to section 6404(e)2 relating to their 1983 taxable years. Petitioners meet the net worth limitations of section 7430(c)(4)(A)(ii).

The only issue for decision is whether respondent's refusal to abate interest for the period of time between April 1, 1985, and July 8, 1996, was an abuse of discretion...

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