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