- 5 - 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 deficiencyPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011