- 14 -
giving on your returns during processing could not be
did [sic] within the authority of the Internal Revenue
Code.
Only mathematical or clerical errors are corrected
during the processing of returns in accordance with
Internal Revenue Code section 6213(b). * * *
All other assessments of tax must be made by using
deficiency procedures which allow a taxpayer to
exercise his/her appeal rights in cases where the
taxpayer does not agree. Therefore, tax issues that
require any proof or documentation to be presented by
the taxpayer may not be corrected during processing.
* * * * * * *
If you do not accept our findings, you may request
reconsideration with our Appeals Office.
Interest will continue to accrue on any unpaid
liability.
Petitioner exercised her administrative appeal rights.
Thereafter, by letter dated August 4, 1999, an Appeals officer in
respondent’s Atlanta Appeals Office advised petitioner that
“Based upon a thorough review of your case my preliminary
evaluation is that no additional interest abatement is
appropriate.” The Appeals officer further wrote:
Your position is that you should not be liable for
interest for the reason that IRS did not challenge your
erroneous deductions for unsupportable charitable
contributions for a number of years prior to the years
for which you were audited. I regret that this does
not fall within the interest abatement provisions of
the Internal Revenue Code.
Petitioner was given 15 days from the date of the letter to
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011