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reviewing the relevant returns. In early 1997, Agent Garner
included petitioners’ 1995 income tax return in the examination.
Respondent issued a 30-day letter to petitioners on June 10,
1997, for the taxable years 1993, 1994, and 1995, and Agent
Garner held a closing conference with petitioner on the same day.
Agent Garner closed the case on July 28, 1997, after receiving a
protest letter from petitioners.
Petitioners’ case was assigned to IRS Appeals Officer Roger
Allen on August 28, 1997. Officer Allen met with petitioner on
December 9, 1997, but he did not work on petitioners’ case
between January 9, 1998, and June 9, 1998, because of his
caseload and other priorities. Officer Allen received
petitioners’ offer of settlement on July 6, 1998, and respondent
received an executed settlement agreement from petitioners on
October 16, 1998. Tax and interest were assessed on November 12,
1998, pursuant to the agreement.
Petitioners submitted a Claim for Refund and Request for
Abatement (Form 843) on February 10, 1999, for tax years 1993,
1994, and 1995. On February 7, 2000, respondent mailed to
petitioners a final determination disallowing petitioners’ claim
for abatement of interest under section 6404(e)(1). Respondent
stated therein that he “did not find any errors or delays that
merit abatement of interest”.
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Last modified: May 25, 2011