Marvin L. White and Phyllis White - Page 3

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          a letter to petitioners denying abatement of the total amount of             
          interest requested in petitioners' claims but in the letter                  
          stated that no interest would be charged for the period from                 
          March 24, 1993, to March 14, 1994.  This letter also advised                 
          petitioners of their right to appeal the Service Center's                    
          determination to an Internal Revenue Service Appeals Office.                 
          Petitioners exercised their appeal rights.                                   
               On January 26, 1996, a final determination letter was issued            
          by the Appeals Office stating that petitioners' claims for                   
          abatement of interest for the taxable years 1979 through 1984                
          were disallowed except that interest was abated for the period               
          from March 24, 1993, to March 14, 1994.  Shortly thereafter, a               
          computation of the amounts of unabated interest was made by a                
          revenue officer on March 28, 1996, pursuant to petitioners'                  
          request.                                                                     
               On September 23, 1996, petitioners filed the petition                   
          commencing this case.  Therein petitioners request that the Court            
          abate the interest assessed for the taxable years 1980, 1981, and            
          1983.  Attached to the petition is a copy of the revenue                     
          officer's letter dated March 28, 1996, including an interest                 
          computation.  Other attachments include a second letter from a               
          revenue officer dated May 16, 1996, and a letter from an Appeals             
          officer dated November 30, 1995.  All of the attachments concern             
          the computation of interest and provide explanations of the                  
          amounts of interest previously assessed for the taxable years                




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