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LANDVOGT v. COMMISSIONER

Docket No. 12189-02.

86 T.C.M. 108 (2003)

T.C. Memo. 2003-217

William and Penny Landvogt v. Commissioner.

United States Tax Court.

Filed July 22, 2003.

Attorney(s) appearing for the Case

William Landvogt and Penny Landvogt, pro sese.

James E. Schacht, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge.

On July 3, 2002, respondent issued a notice of final determination disallowing petitioners' claim for abatement of interest with respect to their 1992, 1993, and 1994 taxable years. Petitioners timely filed a petition under section 6404(h) and Rule 280.1 The issue for decision is whether respondent's denial of petitioners' claim for abatement of interest was an abuse of discretion...

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