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On January 10, 2000, by letter to respondent's Office of the
Taxpayer Advocate in Nashville, Tennessee, petitioner again
requested waiver of the $594 addition to tax and abatement of the
$5 of interest.
By letter dated January 25, 2000, respondent's Nashville
Office of the Taxpayer Advocate informed petitioner that his
requests for waiver of the addition to tax and for abatement of
the interest were denied because it was concluded that
petitioner's $11,000 underpayment of estimated income tax for the
last quarter of 1998 was not caused by casualty, disaster, or
other unusual circumstances and because it was concluded that
imposition of the addition to tax would not be against equity and
good conscience. The letter from respondent also informed
petitioner that he possessed certain “appeal rights”, but the
letter did not explain those appeal rights.
On February 15, 2000, petitioner filed his petition with the
Tax Court seeking relief from the above addition to tax and
abatement of the above interest. At the time the petition was
filed, petitioner resided in the Bronx, New York.
As of November 30, 2000, the date of trial, petitioner had
not filed a Form 843, Claim for Refund and Request for Abatement
of Interest, and respondent had not issued to petitioner a notice
of final determination with regard thereto.
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