Durham v. Comm'r

2004 T.C. Memo. 125, 87 T.C.M. 1365, 2004 Tax Ct. Memo LEXIS 126
CourtUnited States Tax Court
DecidedMay 25, 2004
DocketNo. 5185-02
StatusUnpublished

This text of 2004 T.C. Memo. 125 (Durham v. Comm'r) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Durham v. Comm'r, 2004 T.C. Memo. 125, 87 T.C.M. 1365, 2004 Tax Ct. Memo LEXIS 126 (tax 2004).

Opinion

CHARLES DURHAM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Durham v. Comm'r
No. 5185-02
United States Tax Court
T.C. Memo 2004-125; 2004 Tax Ct. Memo LEXIS 126; 87 T.C.M. (CCH) 1365;
May 25, 2004, Filed

*126 Taxpayer's motion for summary judgment denied. Commissioner's motion for summary judgment granted. Commissioner's decision to not abate interest on unpaid taxes sustained.

Maurice W. Gerard, for petitioner.
Caroline R. Krivacka, for respondent.
Holmes, Mark V.

Mark V. Holmes

MEMORANDUM OPINION

HOLMES, Judge: Section 6404(e) of the Code 1gives the Commissioner power to abate interest that has accrued on unpaid taxes. In 1996, Congress amended the section to allow abatement more often, but made the amendment effective only for interest accruing on tax deficiencies or payments for tax years beginning after the date of enactment -- July 30, 1996. Petitioner, Charles Durham, was under audit for his 1992-94 tax years when the amendment was enacted. He wants to take advantage of the amendment's terms, and so challenges the constitutionality of its effective date. The case comes to us on cross-motions for summary judgment.

*127              Background

Before the 1996 amendment, the Commissioner could abate interest under section 6404(e) only when interest had accrued because of an IRS employee's error or delay in performing a "ministerial act." Sec. 6404(e) (1994) ("old section 6404(e)"); see Woodral v. Commissioner, 112 T.C. 19, 24-25 (1999). But "ministerial act" was narrowly defined as "a procedural or mechanical act that does not involve the exercise of judgment or discretion . . . ." Proced. & Admin. Regs., sec. 301.6404-2T(b)(2), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 30163(Aug. 13, 1987). 2 This definition captured only such bureaucratic snafus as delays in transferring a case between offices or in issuing an already agreed-upon notice of deficiency. Id. Examples (1) and (2).

Congress came to*128 think that other sorts of delays called for relief from the relentless accrual of interest. The 1996 amendment ("new section 6404(e)") therefore empowered the Commissioner to abate interest caused by any "unreasonable error or delay by an officer or employee of the Internal Revenue Service * * * in performing a ministerial or managerial act." Taxpayer Bill of Rights 2, Pub. L. 104-168, sec. 301, 110 Stat. 1452, 1457 (1996) (emphases added). "Managerial" acts include such mistakes as "the temporary or permanent loss of records" and, more generally, mistakes in the "exercise of judgment or discretion relating to management of personnel." Proced. & Admin. Regs., sec. 301.6404-2(b)(1).

Petitioner's problems began in April 1995, when the IRS started to audit his 1992 tax return. The IRS later expanded the audit to his 1993 and 1994 returns. The audit went slowly: in January 1996, the IRS reassigned the first revenue agent working on this case to other matters and didn't put a second agent on it until May 1996. A year later, the case went to the IRS's Appeals Office. The Appeals officer concluded that the audit needed additional work and returned the case to the district office in November*129 1997, where it went into suspended animation.

Respondent blames this on petitioner's attorney, and petitioner blames it on respondent's personnel assignments and mishandling of files. Work finally resumed in early 1999, and the parties closed the case in March 1999 with petitioner's agreeing to the assessment and collection of deficiencies for 1992-94.

In October 1999, petitioner asked respondent to abate at least part of the accrued interest, citing respondent's delays in handling the case. Respondent issued his final determination in August 2001. It completely disallowed petitioner's request, and this appeal followed.

Petitioner has at all relevant times been a resident of Tennessee, and this case was originally set to be tried in Knoxville. Before trial, however, both parties moved for summary judgment. Respondent's motion was simple: Petitioner's allegations of IRS errors all involved "managerial" acts.

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Bluebook (online)
2004 T.C. Memo. 125, 87 T.C.M. 1365, 2004 Tax Ct. Memo LEXIS 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/durham-v-commr-tax-2004.