- 4 - On December 2, 1996, petitioners filed a petition (the 1996 petition) with the Court requesting the abatement of penalties and interest relating to employment taxes for the taxable periods ending June 30 and December 31, 1988 (the 1988 employment taxes). On March 3, 1997, respondent received a Claim for Refund and Request for Abatement (Form 843) from petitioners. On March 17, 1998, respondent filed a motion to dismiss for lack of jurisdiction (motion to dismiss) the 1996 petition on the grounds that a notice of final determination not to abate interest (notice of final determination) on the 1988 employment taxes had not been issued to petitioners. On March 26, 1998, the Commissioner issued a notice of final determination to petitioners related to the 1988 employment taxes. The Commissioner denied petitioners' request for abatement. On April 3, 1998, petitioners opposed respondent's motion to dismiss and lodged with the Court a first amended petition for review of failure to abate interest under section 6404 (the amended petition). In an order dated April 9, 1998, the Court granted respondent's motion to dismiss the 1996 petition. Furthermore, we ordered the amended petition be filed as petitioners' petition for review of failure to abate interest under section 6404, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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