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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
assessed.
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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