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On March 19, 1996, petitioners' daughter wrote to Loren
Peterson (Peterson), respondent’s Appeals officer, to ask how
much respondent claimed petitioners owed for 1979 and 1982
including taxes, interest, and penalties.
On March 23, 1996, petitioners filed with the Ogden Service
Center a request to abate interest (Form 843) that had accrued on
their tax liabilities for 1979 and 1982. On May 3, 1996, the
Ogden Service Center notified petitioners that their request for
abatement was being sent to Andover, Massachusetts, for
processing. On June 19, 1996, petitioners received a telephone
call from Larry Landon (Landon) of the Andover Service Center.
Landon said that their request for abatement would be handled by
respondent's Phoenix Appeals office.
On June 20, 1996, petitioners’ daughter wrote Peterson to
ask whether petitioners' request for abatement should be handled
by his office. She asked Peterson for copies of all documents
relating to petitioners' 1979 and 1982 taxes, especially
pertaining to Signature and Encoder. On July 12, 1996,
petitioner met with Peterson.
On November 22, 1996, petitioners signed a second request
for abatement of interest (Form 843) for their 1979 and 1982
years.
A notice of trial on December 9, 1996, was served on
September 18, 1996. On December 9, 1996, the parties reported
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Last modified: May 25, 2011