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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, it
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