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July 27, 1998, a Claim for Refund and Request for Abatement. In
her claim, petitioner requested that interest on her 1995
deficiency in income tax be abated or refunded because of “IRS
errors or delay”. In this regard, petitioner recited in her
claim:
Job failure by IRS strips taxpayer of their rights.
Abatement of interest should be easy.
See infra subdivision E of our Findings of Fact regarding
action by respondent on petitioner’s claim for abatement of
interest.
E. Action by Respondent on Petitioner’s Claims for Abatement
By letter dated October 27, 1998, which referenced the
taxable years 1993, 1994, and 1995, respondent’s Problem
Resolution Office in the Atlanta Service Center advised
petitioner, in part, as follows:
We reviewed each one of your claims for abatement
of interest under the provisions of Internal Revenue
Code Section 6404(e)(1) & (2). For 1993 we have
partially allowed your claim for $89.63 in interest.
For 1994 and 1995, it has been determined that
there were no errors or delays relating to ministerial
acts performed during the audits of these two tax
years. We have therefore, issued a certified
disallowance letter for both years. You may appeal the
decision to disallow these claims for 1994 and 1995.
You may also appeal the partial disallowance of your
claim for 1993.
By certified letter also dated October 27, 1998, which
referenced just the taxable year 1993, the director of
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