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Interest accrued on petitioner's tax liability for 1985 as
follows:
Period Interest
Apr. 15, 1986 - Apr. 11, 1993 $4,022.76
Apr. 12, 1993 - Aug. 8, 1995 1,106.81
Aug. 9, 1995 - date of trial 1,354.30
Petitioner meets the net worth requirements under 28 U.S.C.
section 2412(d)(2)(B) (1994).
Petitioner petitioned this Court to review respondent's
refusal to abate interest in the amount of $5,426.38.4
Petitioner also alleged in the petition that he is not liable for
additions to tax (other than that which he already paid in
installments), that respondent improperly levied his bank
account, and that he may offset his 1985 income tax liability
with a refund from 1995. Respondent filed an answer generally
denying the contentions in the petition.
At trial, respondent filed a motion to dismiss for lack of
jurisdiction over the part of the case with respect to
petitioner's claim for abatement of penalties and wrongful levy.
OPINION
A. Whether We Have Jurisdiction To Decide Petitioner's
Contentions About a Wrongful Levy, Refund Offset, and
Liabilities for Additions to Tax or Penalties
1. Wrongful Levy
Petitioner contends that respondent's collection of $127.96
from the levy issued on August 17, 1997, was improper because it
4 At trial, the parties stipulated that the correct amount
of assessed accrued interest in dispute is $5,284.44.
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