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internal document from the IRS dated July 29, 1997, indicates
that petitioners' interest abatement claim had previously been
filed and denied and that no further claims would be considered.
On August 27, 1997, petitioners wrote to respondent seeking to
appeal the disallowance of their interest abatement claim. In a
response dated December 10, 1997, John Tagliamento, Chief of the
Joint Compliance Branch in Fresno, informed petitioners that
their request for abatement of interest had been disallowed and
that petitioners would have to pay the interest and seek a refund
in the Federal District Court or the Court of Federal Claims.
However, a little more than a week later, Jerry Li, an IRS
employee with the San Francisco Appeals Office, wrote to
petitioners in response to an earlier telephone call. Mr. Li
informed petitioners that their request for abatement of interest
had been disallowed by Appeals Officer Sivick on March 8, 1996,
and that the Tax Court had jurisdiction to review such matters.
Mr. Li enclosed with his letter a sample of a final determination
letter disallowing a request for abatement of interest, inquired
whether petitioners had received such a letter, and provided
petitioners with the Court's address so they could request a form
petition.
On January 27, 1998, respondent's Fresno Appeals Office
received a third Form 843 from petitioners dated January 16,
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