Nina H. Pettyjohn - Page 12




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          respondent’s Atlanta Service Center advised petitioner of                   
          respondent’s intention to abate interest on petitioner’s $2,115             
          deficiency in income tax for 1993 for the period from August 22,            
          1996, to July 7, 1997.  The letter stated, in part, as follows:             
               After an extensive review of your file, we have                        
               determined that the provisions of the Internal Revenue                 
               Code Section 6404(e)(1) apply to the following time                    
               period and amount:                                                     

               Period: August 22, 1996 to July 7, 1997  Amount: $89.63                

               The reason for the allowance of this amount is that                    
               there was a ministerial delay in associating your reply                
               to the original 30-day letter with the case file.  The                 
               reply was received in the Atlanta Service Center on                    
               August 22, 1996.  No action had been taken in regards                  
               to this information until the Appeals Officer presented                
               you with a settlement on July 7, 1997.  We have                        
               therefore abated the accrual of interest on the balance                
               of tax owed after your payment of $1,500.00 (received                  
               on August 22, 1996) was applied.  Your balance of                      
               $615.00 had interest accruals totaling $89.63 for this                 
               time period.                                                           

                  *       *       *       *       *       *       *                   

               * * * The interest abatement only applies to the period                
               shown above.                                                           

               If your claim has not been allowed in full for the time                
               period and amount requested, you may request reconsideration           
               with our Appeals Office.                                               

               Interest will continue to be charged on any unpaid                     
               liability, except for the above abatement period.                      

               Subsequently, respondent abated $89.63 of interest on                  
          petitioner’s deficiency in income tax for 1993.                             
               By a second certified letter also dated October 27, 1998,              





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