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income from KSCI, as well as KSCI’s deducting office expenses
to which it was not entitled. On their 1992 and 1993 Forms
1040, the Chans reported $6,109 and $6,289, respectively, as
income from KSCI. Appeals determined that petitioner received
income of $42,755 in 1992 and $42,803 in 1993 from KSCI, and
petitioner agreed to deficiencies and additions to tax based on
the receipt of that income.
We are unpersuaded by petitioner’s argument that
respondent’s erroneous determination that KSCI was a personal
holding company prevented him from settling earlier with
respondent and thereby directly caused the assessment of
interest in this case. Nothing in the record suggests that
petitioner made any attempt to pay or acknowledge the
deficiencies in tax attributable to his failure to report
taxable income from KSCI.
Further, petitioner’s reliance on the fact that it took the
Appeals officer only one meeting with Mr. Chan to agree to the
appropriate tax adjustments does not support his theory that
the interest covering the entire period for which he seeks
abatement is attributable to the examining agent’s improper
application of the personal holding company provisions.
Petitioner’s first meeting with Mr. Matos took place on January
4, 1995. At that meeting petitioner provided Mr. Matos with
various KSCI records, and Mr. Matos requested that additional
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