Robert Banat - Page 3




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          Background                                                                  
               Petitioner filed his Federal income tax returns for 1985,              
          1986, and 1987 on May 15, 1986, August 16, 1987, and April 15,              
          1988, respectively.                                                         
               Petitioner was contacted in writing with respect to a                  
          deficiency in his 1985 Federal income tax liability no later than           
          July 22, 1986.  He was contacted in writing with respect to a               
          deficiency in his 1986 Federal income tax liability no later than           
          November 1, 1988.  He was contacted in writing with respect to a            
          deficiency in his 1987 Federal income tax liability no later than           
          June 13, 1990.                                                              
               On March 19, 1992, with respect to petitioner’s 1985 taxable           
          year, respondent assessed an additional tax of $21,121 and                  
          interest of $21,946.11.  Also, on March 19, 1992, with respect to           
          petitioner’s 1986 taxable year, respondent assessed an additional           
          tax of $6,418 and interest of $5,662.08.  On April 5, 1993, with            
          respect to petitioner’s 1987 taxable year, respondent assessed an           
          additional tax of $8,715 and interest of $6,617.74.                         
               On August 13, 1995, petitioner submitted three Forms 843,              
          Claim for Refund and Request for Abatement (the Forms 843), to              
          respondent, one each for his taxable years 1985, 1986, and 1987             
          each claiming an abatement of interest.  None of the Forms 843              
          specifies the amount of interest to be abated or the period                 
          during which the interest to be abated accrued.  Respondent                 





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