Seymour and Beatrice Leffert - Page 16




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          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).                                              








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