Christine A. Dormer - Page 8

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          December 4, 2002.  The Form 843 requested abatement of interest             
          and penalty for the year 1998 in the amount of $2,026.91.                   
          Petitioner’s request was assigned to Appeals Officer Michael                
          Bibb, and on April 24, 2003, an Appeals conference was held to              
          discuss petitioner’s Form 843.  On May 22, 2003, respondent                 
          issued a Full Disallowance--Final Determination, denying                    
          petitioner’s request for abatement.  Petitioner’s petition                  
          seeking review of respondent’s failure to abate interest under              
          section 6404 was filed with this Court on June 30, 2003.  The               
          petition claims that respondent’s determination is based on the             
          following error:  “The Petitioner and the Internal Revenue                  
          Service agreed upon and reached a full and final settlement of              
          all disputed issues, as a consequence of which the Internal                 
          Revenue Service’s attempts to collect additional interest are               
          erroneous.”                                                                 
                                       OPINION                                        
          I.  General Rules                                                           
               A.  Section 6404 Generally                                             
               Section 6404(e) provides, in relevant part, as follows:                
                    SEC. 6404(e).  Abatement of Interest Attributable                 
               to Unreasonable Errors and Delays by Internal Revenue                  
               Service.--                                                             
                         (1) In general.-- In the case of any                         
                    assessment of interest on--                                       
                              (A) any deficiency attributable in whole                
                         or in part to any unreasonable error or delay                
                         by an officer or employee of the Internal                    





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