- 12 - assume the IRS had closed the Blue Gem case without adjusting Blue Gem’s 1982 and 1983 returns, thus confirming that the Blue Gem coal mining venture was a legitimate investment. On March 24, 1997, the IRS made an assessment against petitioners of tax and interest attributable to the disallowance of Mr. Leffert’s distributive share of Blue Gem losses for 1982 and 1983. On April 3, 1997, the IRS sent a letter to Mr. Leffert responding to his March 9, 1997, letter. Though disagreeing with Mr. Leffert’s claim that there had been an inordinate delay, the IRS advised him that he could file a Form 843, Claim for Refund and Request for Abatement, if he wished to dispute the interest assessed against him. The letter further advised Mr. Leffert that his request for abatement would be denied by the Service Center but that he could appeal that decision administratively. On April 16, 1997, Mr. Leffert sent a letter to the IRS reiterating that he had never received notice of the IRS’s decision concerning his earlier protest letter until about March 1997, when he had received the Forms 4549-A. He asked that some compromise be made allowing petitioners to pay interest only through December 31, 1988. On August 11, 1997, petitioners filed their request for abatement of interest for 1982 and 1983. Their Form 843 stated in pertinent part:Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011