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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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