Case: Taxpayer Not Entitled to Interest Abatement Where Accumulation Was Not Caused by Delay of IRS (T.C. Bench) (§6404)

Taxpayer was not entitled to abatement of interest where he did not allege the delay was caused by an IRS employee’s ministerial or managerial act, held the U.S. Tax Court in a bench opinion. Despite his best efforts, Taxpayer was unable to roll over his 401(k) when he switched jobs and was forced to withdraw the funds, which he reported on his tax return, triggering an assessment and penalty. Taxpayer was able to get the penalty eliminated, but paid the tax late, which therefore included interest. Because the IRS abated the penalty due to Taxpayer’s reasonable efforts, he requested an ...