Edgar and Doris Brown - Page 5




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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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