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On September 14, 1995, petitioner wrote a letter to
respondent in which he stated that he had made his final payment
of $180.24 for his 1985 tax liability and asked respondent to
abate the $6,019.10 claim. On April 21, 1996, petitioner filed a
Claim for Refund and Request for Abatement (Form 843) for his
1985 tax year, in which he asked respondent to abate interest
that had accrued because of respondent's errors and delays and
additional but unspecified, penalties. Petitioner contacted
respondent's Problem Resolution Office in August 1996. The case
was assigned to the Problem Resolution Office by August 29, 1996.
On September 12, 1996, respondent abated $352.11 of interest
that had accrued from March 1, 1995, to August 7, 1995, but
otherwise rejected petitioner's request without providing any
helpful explanation. In that letter, respondent's Problem
Resolution Program staff said:
We are sorry, but we cannot allow your request to
remove all of the interest charged for the tax period
shown above [ending December 31, 1985]. This letter is
your notice that your request is partially disallowed.
We allowed only $352.11 of the request for the
following reasons:
Interest waiver applies from March 1, 1995, through
August 7, 1995. A notice was issued on March 1, 1995,
giving you an erroneous payoff amount which you paid.
The prior notices issued cannot be considered because
the total payoff amounts were not paid. On August 7,
1995 a notice was issued giving you a correct payoff
amount. For your information, enclosed is a detailed
interest computation of your tax account for 1985.
The current balance due for the tax period ended
December 31, 1985, is $5,159.23, which includes
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