Nina H. Pettyjohn - Page 7




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               3.  Payment of Petitioner’s Account Balance                            
               As of February 9, 1998, petitioner’s account balance was               
          $1,217.67, calculated as follows:                                           
               Date          Event                  Amount                            
               Aug. 22, 1996   Advance payment        ($1,500.00)                     
               Feb. 9, 1998    Assessment/tax           2,115.00                      
               Feb. 9, 1998    Assessment/interest        602.67                      
               1,217.67                                                               

               By October 13, 1999, petitioner’s account was fully paid               
          through:  (1) The application of overpayments of income tax                 
          claimed by petitioner on her 1997 and 1998 income tax returns,              
          see sec. 6402(a); (2) subsequent payments by petitioner; and (3)            
          the abatement of interest, described infra in subdivision E of              
          our Findings of Fact.                                                       
               4.  Petitioner’s Claim for Abatement of Interest                       
               Using Form 843, petitioner filed with respondent on or about           
          July 27, 1998, a Claim for Refund and Request for Abatement.  In            
          her claim, petitioner requested that interest on her 1993                   
          deficiency in income tax be abated or refunded because of “IRS              
          errors or delay”, specifically, IRS tax examiners’ “failure in              
          job performance”.                                                           
               See infra subdivision E of our Findings of Fact regarding              
          action by respondent on petitioner’s claim for abatement of                 
          interest.                                                                   








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