- 3 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011