- 8 - that interest had been paid as of March 26, 1993. By letter dated January 24, 2001, respondent notified petitioners that $7.14 of interest that accrued from March 26, 1993, to July 14, 2000, would be abated but denied petitioners’ request for abatement of interest that had accrued before March 26, 1993. By letter dated February 23, 2001, petitioners requested that respondent’s Appeals Office reconsider the portion of their abatement claim that had been denied. In this letter, petitioners identify “a number of delays”, one of which erroneously lists the date of the revenue agent’s report as December 16, 1992, when, in fact, as noted above, the report was issued on December 16, 1991. The letter goes on to allege that petitioners’ abatement claim (received by respondent on June 27, 2000) “was filed * * * shortly after assessment of the interest in this case”. As noted, with the exception of $8.61, all of the interest that had previously accrued was assessed and paid as of March 26, 1993. Petitioners’ use of the term “shortly” is expansive, to say the least. The Appeals officer assigned to the matter prepared a detailed chronology of events relevant to the determination of petitioners’ 1989 Federal income tax liability. Petitioners apparently were provided a copy of this chronology before February 23, 2001, as their letter to respondent on that date makes reference to it. In a note included within the chronologyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011