- 6 - 1998. On April 1, 1998, Appeals Officer Sivick wrote a letter to petitioners which states in pertinent part: I have been told by my National Office Liaison that I am to reject your Form 843 Claim for abatement of interest under Code Section 6404(e)(1). Back in 1996 I considered a previous request for abatement of interest and I made the decision that no interest should be abated. It is the Service's position that claims denied prior to the enactment of the provisions of the Taxpayer's Bill of Rights 2 (July 30, 1996) will not be given the opportunity to re-file their claims in an attempt to petition the United States Tax Court. Therefore this letter does not qualify as a Final Determination Letter as I am merely notifying you that your Form 843 is being rejected rather than denied since you have already had the merits of your case considered under the provisions of law in effect at the time your claim was considered. All of the Forms 843 that petitioners submitted to respondent refer to the tax period as January 1 through December 31, 1990. All of the Forms 843 present the same claim, that the settlement of docket no. 7495-94S, which concerned a deficiency for the taxable year 1990, included a compromise of all taxes and interest. The Form 843 submitted on January 27, 1998, seeks an abatement of $3,051.90, in contrast to the original abatement request which sought an abatement of $2,453.69. We assume that the difference is the continual accrual of interest during the intervening period. On September 24, 1998, petitioners filed a petition in the instant case seeking review of respondent's denial of theirPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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