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Year Increase in Tax Interest Charged
1982 $5,410 $22,290.18
1983 5,763 20,992.39
1984 366 821.45
On or about February 12, 1998, Ms. Clark, on behalf of all
petitioners, paid respondent the $11,539 in taxes specified in
the notices.
Sometime after receiving the September 29, 1997, notices,
petitioners requested that respondent abate the interest charged.
On January 20, 1999, respondent notified Ms. Clark that the claim
for abatement of interest under section 6404(e) was disallowed.
On July 16, 1999, petitioners filed a timely petition for Review
of Denial of Request for Abatement of Interest. In that petition
Ms. Clark also requested she be relieved from joint liability as
to the relevant years.
Respondent moved to strike Ms. Clark’s claim for relief from
joint liability from the petition. Respondent asserts that the
Court lacks jurisdiction with regard to that claim. Petitioners
opposed that motion. Respondent responded stating in part:
“After a diligent search of our records, respondent has
determined that no claim or election for relief under I.R.C. �
6015 (b) or (c) was filed by petitioner Ms. Clark, f.k.a. Dorothy
E. Wenner, with the Internal Revenue Service in accordance with
normal procedures.”
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Last modified: May 25, 2011