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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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