- 13 - On July 8, 1996, respondent mailed an FPAA to petitioners James and Janice Geis. A Form 870-P(AD) was mailed to petitioners Laurence and Patricia Jacobs on August 14, 1995, but they did not sign the settlement letter until June 30, 1996. The OSC received the Jacobses' settlement letter on July 11, 1996. As of the date of the Geises' letter finally determining that interest would not be abated, the Geises' total interest liability was $21,298.31 and their assessed interest was $734.77 for tax year 1983. The Geises have not made any payments of interest. As of the date of the Jacobses' letter finally determining that interest would not be abated, the Jacobses' total interest liability was $17,629.17 for tax year 1983. The Jacobses made the following payments of interest which relate to the TLP issue: $10,000 on or around August 6, 1998; $9,231.84 on or around August 31, 1998; and $300.91 on or around October 7, 1998. Discussion Pursuant to section 6404(e)(1), as it applies to the instant case,8 the Commissioner may abate part or all of an 8 Congress amended sec. 6404(e) during 1996 to permit abatement of interest for any "unreasonable" error and delay in performing a ministerial "or managerial" act. Taxpayer Bill of Rights 2 (TBOR 2), Pub. L. 104-168, sec. 301(a)(1) and (2), 110 Stat. 1452, 1457 (1996). That amendment, however, applies only to tax years beginning after July 30, 1996, and, therefore, does (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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