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(2) a levy on petitioner’s account at the Lockheed Credit Union.7
3. Petitioner’s Claim for Abatement of Interest
Using Form 843, petitioner filed with respondent on or about
September 4, 1998, a Claim for Refund and Request for Abatement.
In her claim, petitioner requested that interest on her 1994
deficiency in income tax be abated or refunded because of “IRS
errors or delay”.
See infra subdivision E of our Findings of Fact regarding
action by respondent on petitioner’s claim for abatement of
interest.
D. The Taxable Year 1995
1. Petitioner’s 1995 Tax Return and Notice of Deficiency
Petitioner timely filed a Federal income tax return for
1995. See sec. 6072(a).
In or about October 1996, petitioner was notified in writing
of the examination of her 1995 income tax return through the
receipt of an examination report dated October 4, 1996. The
examination report proposed a deficiency in income tax of $9,698.
The proposed deficiency was principally attributable to the
disallowance of the deduction claimed by petitioner for gifts to
family members of $37,510.
7 A credit balance in petitioner’s account with respondent,
which was attributable to an excess of proceeds received through
the levy, was refunded to petitioner on Apr. 28, 1997.
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