Gregorio and Viviana Mankita - Page 6




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          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 to           




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