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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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