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changes being asserted with respect to most of the taxable years
under examination. The correct tax liabilities for all of the
years were contained in final determinations sent on or before
October 19, 1998. Although the terms of the settlement remained
substantially the same as those communicated to petitioners in
1991, the overall correct tax liability was in an amount greater
than Mr. Quinn had anticipated on the basis of his understanding
of those terms at that time.
Before resolution of the issues with respect to all the
years involved in the settlement, the IRS began to collect
assessed tax liabilities. On January 21, 1998, the IRS levied
upon petitioners’ bank account in connection with taxable years
1985, 1986, 1988, and 1989. The levy was not for the correct
amounts of tax ultimately determined for those years. On August
31, 1998, the IRS notified petitioners that it intended to levy
to collect tax owed for 1991. The amount stated in this notice
also was not the amount ultimately determined to be due for that
year.
Petitioners requested an abatement of interest accruing from
January 1, 1992, through November 5, 1998, with respect to
underlying deficiencies for tax years 1983 through 1986 and 1988
through 1991.2 Respondent made a final determination that
2 This was an amended request for abatement. According to
the stipulation of facts, petitioners filed an initial request
(continued...)
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