Robert and Linda Yuen - Page 5




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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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