John B. Cosgriff - Page 4

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          requesting assistance in resolving his disagreement with the                
          Internal Revenue Service.  Senator Bryan inquired about                     
          petitioner’s situation.  As a result, respondent reopened                   
          petitioner’s case in August of 1996 and reconsidered the 1992               
          return.  This time, petitioner provided receipts and information            
          concerning his 1992 Schedule C automotive business.  On the basis           
          of the information provided, respondent abated $1,125 of the                
          deficiency, $539 in penalties, and $56.81 in interest.  On                  
          October 7, 1996, respondent denied petitioner’s subsequent                  
          request for appellate consideration.                                        
               On April 2, 1997, petitioner filed a Form 843, Claim for               
          Refund and Request for Abatement.  On August 15, 1997, respondent           
          notified petitioner than no penalties would be imposed but that             
          interest would not be abated.  This notice invited petitioner to            
          request consideration with respondent’s Appeals Office within 30            
          days.  On September 15, 1997, petitioner requested that his claim           
          for interest abatement be reconsidered by the Phoenix Appeals               
          Office.  On April 23, 1998, the Appeals Office denied                       
          petitioner’s claim for abatement of interest but notified him               
          that the case would be held open for 2 weeks to allow him an                
          opportunity to provide additional information.  On May 23, 1998,            
          respondent issued a notice of final determination denying                   
          petitioner’s claim for abatement of interest.  Petitioner timely            

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