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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.
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