- 16 - has contacted the taxpayer in writing about the deficiency or payment in question. See sec. 6404(e). Petitioners requested that respondent abate interest for the period from December 31, 1988, through August 1997. Respondent denied petitioners’ request, claiming that the record does not disclose any erroneous or dilatory performance of a ministerial act by an officer or employee of the IRS, and issued a notice of final determination to petitioners. Petitioners filed a timely petition to contest respondent’s determination. We have jurisdiction to decide whether respondent abused his discretion in determining that no interest abatement was appropriate. We shall organize and conduct our analysis by segmenting it into the relevant time periods. December 31, 1988, Through March 13, 1990 Following the receipt of Mr. Leffert’s protest letter by the Brookhaven Service Center, a case manager in the Manhattan District Office determined, on March 30, 1989, that the letter should be processed by the New York City Appeals Office. As a result, Appeals Officer Koniarski was assigned the Blue Gem case on June 5, 1989. Mr. Koniarski then attempted to schedule conferences with the Blue Gem TMP and any interested notice partners, including 7201 Associates (on whose behalf Mr. Leffert had filed the protest letter).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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