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On May 29, 1997, respondent received $11,622 pursuant to a
notice of levy on petitioners’ bank account. This amount was
applied to petitioners’ balance due for taxable year 1989. On
June 3, 1997, petitioners paid in full the balances due for
taxable years 1989 and 1990, including interest of $14,687 for
1989 and $13,483 for 1990.
On June 21, 1997, petitioners filed Form 843, Claim for
Refund and Request for Abatement, for taxable years 1989 and
1990. Petitioners requested abatement of interest in the amounts
of $10,038 for taxable year 1989 and $11,039 for taxable year
1990. On July 7, 1997, petitioners also filed Forms 843
requesting refunds approximating the total tax, penalties, and
interest assessed for taxable years 1989 and 1990.
On April 13, 1998, respondent issued a notice of final
determination disallowing petitioners’ June 21, 1997, claim for
abatement of interest. On August 26, 1998, respondent issued a
notice disallowing petitioners’ July 7, 1997, claims for refunds.
Discussion
In seeking abatement of respondent’s assessment of interest,
petitioners have alleged that respondent erred in the
determination, assessment, and collection of their Federal income
taxes, and that they were improperly denied their right to
petition this Court to review respondent’s deficiency
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