James Edward Crawford - Page 12




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          be used sparingly, and it did not intend that abatement “be                 
          used routinely to avoid payment of interest.”  Id.                          
               Petitioner currently argues that his interest should be                
          abated because he counted on receiving a tax "credit" of $5,717             
          from 1983 toward the payment of his 1980 tax deficiency in                  
          accordance with written and oral advice he received from                    
          "several" IRS employees prior to filing a petition in the Tax               
          Court.  He states now that he would have returned the $6,330                
          check, which he at one time claimed he did not receive, but for             
          the "erroneous" advice given to him.                                        
               Petitioner's statement of the facts in his case has evolved            
          to its present form.  From October 1989 until April of 1993,                
          petitioner represented to respondent that he had not received               
          the $6,330 refund he had requested on Form 1045.  After signing             
          a decision document agreeing that there were deficiencies in                
          his Federal income taxes for 1980 and 1983, he formulated a new             
          position.  His new position is that it was the fault of the IRS             
          that he received the $6,330 refund "in error".  Furthermore, he             
          now states that he sought a redetermination of his deficiencies             
          only because several persons at IRS told him that he had a tax              
          "credit" of $5,717 that would be deducted from the $6,330                   
          refund if he lost his case in Court.                                        
               Petitioner has presented no evidence of the "advice" he                
          claims he received from IRS employees, other than his own                   






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