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the Court has jurisdiction pursuant to section 6404(g) to review
respondent's determination denying petitioners' claims for
abatement of interest. The resolution of this issue turns on the
effective date of section 6404(g). Unless otherwise indicated,
all section references are to the Internal Revenue Code in effect
at the time the petition was filed.
Background
Petitioners are husband and wife who resided in Wenatchee,
Washington, at the time the petition was filed.
Following the conclusion of deficiency proceedings, on
December 17, 1992, respondent made assessments of deficiencies
and additions to tax for the taxable years 1979 through 1984.
Petitioners paid $387,429.58, on April 8, 1993, which represented
a payment of the assessments indicated as due on their 1979
through 1984 accounts as calculated by a revenue officer who was
assigned for collection. It was subsequently determined that
additional interest was due. Petitioners contacted an Internal
Revenue Service Problem Resolution Office and, on February 25,
1994, that office sent a letter to petitioners that included a
computation of interest to March 14, 1994. These computations
omitted computations of interest accruing from April 8, 1993, to
March 14, 1994.
On December 26, 1994, petitioners filed claims with the
Fresno Service Center requesting abatement of interest for the
taxable years 1979 through 1984. The Fresno Service Center sent
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