- 15 - F. Petitioner’s Claim for Abatement On August 24, 1998, respondent issued petitioner a notice indicating that the balance due on his income tax liability for 1986 was $24,989.86. Of this amount, $24,230.89 pertained to interest and the balance to one or more penalties. On February 5, 1999, petitioner filed a claim for abatement of interest and penalties for 1986. On April 7, 1999, respondent sent petitioner a letter stating that respondent could not allow petitioner’s claim for abatement of interest and penalties. Thereafter, on June 2, 1999, respondent’s Appeals Office sent petitioner a Notice of Final Determination formally disallowing petitioner’s claim for abatement. The notice stated, in part, as follows: Although delays occurred from the date of the initial contact letter * * * until 5/11/98 when the second tax abatement was granted, the delay was not caused by a Service employee. The delay appears to have been caused when you relied on an unauthorized representative to represent you on the examination of your 1986 tax return. When no protest was received in response to the audit report mailed to you on 10/31/89 the case was forwarded for issuance of the statutory notice of deficiency. The statutory notice of deficiency was issued 3/19/90 and when you did not file a petition with Tax Court within the 90-day period, the tax assessment was made 8/20/90. Subsequent to this, you provided information to warrant a $23,785.64 tax abatement on 5/27/96 and furnished additional information to justify another tax abatement in the amount of $9,453.66 on 5/11/98. The information was not provided to the examiner prior to issuance of the statutory notice of deficiency. Once the information was provided in 1996 and 1998, itPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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