- 3 - 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. RespondentPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011