- 6 - proposed settlement, claimed interest should be abated because Morrow should have finished the audit more quickly, contended that petitioner’s expenses that he incurred to obtain records should offset taxes due, pointed out that they could not tell whether they received credit for Social Security and Federal and State income taxes paid, and notified respondent of their plan to pay in installments. Keenan made no adjustments based on the March 7, 1995, facsimile message. Petitioners agreed to the proposed settlement on April 17, 1996. Keenan's supervisor approved the settlement with petitioners on May 31, 1996. As a result of the settlement, respondent abated $175,766 in tax and $56,216.95 in interest on September 30, 1996. Later, respondent corrected a math error that favored petitioners. Respondent assessed $5,871 in net additional tax and interest as a result of the settlement. In response, petitioners paid $3,380 (on dates not stated in the record). E. Petitioners' Claim for Abatement and Tax and Interest Due Petitioners filed a Form 843, Claim for Refund and Request for Abatement, with respondent on October 7, 1996, in which they asked that all interest and penalties relating to their 1990 year that accrued from August 22, 1994, to September 30, 1996, be abated. On April 18, 1997, respondent mailed to petitioners a notice denying petitioners' claim for abatement. On July 10, 1997, petitioners' petition was filed in this Court. In it, petitioners ask us to abate all interest and penalties related toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011