Robert and Linda Yuen - Page 4

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          entire tax liability for 1990 when respondent accepted                      
          petitioners' payment by check which contained the statement                 
          "compromise settlement in full".                                            
               On or about October 23, 1995, respondent's Ogden Service               
          Center sent a letter to petitioners stating that petitioners'               
          request for abatement of interest for 1990 had been denied on the           
          ground that petitioners had failed to show that the interest                
          owing was attributable to an error or delay caused by an Internal           
          Revenue Service (IRS) employee performing a ministerial act.  The           
          letter further stated that the decision entered in petitioners'             
          Tax Court case indicated that statutory interest would be                   
               On or about November 8, 1995, petitioners filed a protest of           
          the denial of their request for abatement of interest with                  
          respondent's Fresno Appeals Office.  Petitioners' protest                   
          repeated the allegations contained in petitioners' Form 843 dated           
          September 19, 1995.  On March 8, 1996, the Fresno Appeals Office            
          issued a detailed, three-page letter denying petitioners'                   
          interest abatement request in full.  Appeals Officer Paul Sivick            
          was listed as the contact person in the March 8, 1996, letter.              
               On May 12, 1997, respondent received a second Form 843 from            
          petitioners dated May 8, 1995.  (There is no explanation in the             
          record for the 2-year lapse between the date the Form 843 was               
          purportedly signed and the date that respondent received it.)  An           

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