Seymour and Beatrice Leffert - Page 12




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          assume the IRS had closed the Blue Gem case without adjusting               
          Blue Gem’s 1982 and 1983 returns, thus confirming that the Blue             
          Gem coal mining venture was a legitimate investment.                        
               On March 24, 1997, the IRS made an assessment against                  
          petitioners of tax and interest attributable to the disallowance            
          of Mr. Leffert’s distributive share of Blue Gem losses for 1982             
          and 1983.                                                                   
               On April 3, 1997, the IRS sent a letter to Mr. Leffert                 
          responding to his March 9, 1997, letter.  Though disagreeing with           
          Mr. Leffert’s claim that there had been an inordinate delay, the            
          IRS advised him that he could file a Form 843, Claim for Refund             
          and Request for Abatement, if he wished to dispute the interest             
          assessed against him.  The letter further advised Mr. Leffert               
          that his request for abatement would be denied by the Service               
          Center but that he could appeal that decision administratively.             
               On April 16, 1997, Mr. Leffert sent a letter to the IRS                
          reiterating that he had never received notice of the IRS’s                  
          decision concerning his earlier protest letter until about March            
          1997, when he had received the Forms 4549-A.  He asked that some            
          compromise be made allowing petitioners to pay interest only                
          through December 31, 1988.                                                  
               On August 11, 1997, petitioners filed their request for                
          abatement of interest for 1982 and 1983.  Their Form 843 stated             
          in pertinent part:                                                          






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