- 9 - abatement. On January 14, 1999, the IRS mailed a letter to petitioner disallowing an abatement of interest. On January 25, 1999, petitioner mailed the IRS a certified letter replying to the IRS’s disallowance of his request for abatement of interest and penalties. On March 29, 1999, an IRS Appeals officer mailed a letter to petitioner disallowing petitioner’s abatement claims, and a final determination letter was issued on May 6, 1999. On October 9, 1999, petitioner’s Petition for Review of Failure to Abate Interest Under Code Section 6404 on the assessed tax deficiencies for 1992 and 1993 was filed with the Court. Respondent concedes that interest on the tax deficiencies assessed with respect to petitioner and his wife should be abated pursuant to section 6404(e) for the period from February 2 through December 31, 1996. Petitioner concedes that the interest that accrued before October 20, 1994, should not be abated. Discussion Pursuant to section 6404(i),1 the Tax Court has the authority to review the Commissioner’s denial of a taxpayer’s request for abatement of interest. The Court may order an abatement where the Commissioner’s failure to abate interest was 1 Sec. 6404(i) was formerly designated sec. 6404(g) but was redesignated sec. 6404(i) by the Internal Revenue Service Restructuring & Reform Act of 1998, Pub. L. 105-206, secs. 3305(a), 3309(a), 112 Stat. 685, 743, 745.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011