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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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