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Background
On May 9, 1994, Robert and Linda Yuen (petitioners) filed a
petition for redetermination with the Court (assigned docket No.
7495-94S) contesting a notice of deficiency that respondent had
issued to petitioners for 1990. On March 15, 1995, the Court
entered a stipulated decision in docket No. 7495-94S, which
stated that petitioners are liable for a deficiency in income tax
for 1990 in the amount of $6,821 and that petitioners are not
liable for the accuracy-related penalty under section 6662. The
stipulated decision further stated that petitioners agreed to
waive the restrictions that normally would prohibit the
assessment and collection of the deficiency and statutory
interest until the decision of the Tax Court was final.
On or about September 19, 1995, petitioners filed with
respondent a Form 843, Claim for Refund and Request for
Abatement, requesting that respondent abate interest for the
taxable year 1990 in the amount of $2,453.69. Petitioners
asserted in their request that the "IRS had conceded its errors
during 1-18-95 meeting" and that petitioners' liability for
interest for 1990 had been compromised as part of the
negotiations leading to the entry of the stipulated decision in
docket No. 7495-94S. Petitioners further asserted that
respondent had acknowledged that the stipulated decision in
docket No. 7495-94S represented a compromise of petitioners'
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Last modified: May 25, 2011