- 4 - a $100 failure to pay penalty for 1990 and 1991. At that point all assessments for 1988, 1990, and 1991 had been paid, however, some additional interest for each of the years 1988, 1990, and 1991 had not been assessed. On November 4, 1996, respondent issued a Notice of Intent to Levy with respect to unpaid interest in the following amounts: Year: 1988 1990 1991 Amount: $676 $600 $491 Petitioner paid without delay. Petitioner sought a refund of the interest and his claim was denied. Petitioner appealed and on March 13, 1997, respondent abated part of the $100 late payment penalties which petitioner had added to his May 1996 payments. Insofar as petitioner's dispute constituted a claim for refund of interest, respondent determined that petitioner was not entitled to relief pursuant to section 6404(e) and mailed petitioner a Notice of Disallowance. OPINION Petitioner argues that respondent abused his discretion in not abating the interest that accrued on petitioner’s 1988, 1990, and 1991 liabilities. Petitioner argues he was provided with amounts of his total liability for tax, penalties, and interest in a telephone conversation with an employee of respondent on May 9, 1996. Petitioner contends these amounts when paid should have satisfied his liability for interest.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011