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January 22, 1999, a copy of the partnership’s limited partnership
agreement. The Appeals Office (Appeals) informed petitioner’s
counsel that it was sustaining respondent’s denial. In a letter
dated February 11, 1999 (Appeals’ denial), respondent informed
the estate that the estate’s creditors must be paid before
beneficiaries; the estate had sufficient liquidity to pay the
tax; and the estate could borrow additional funds if necessary.
On February 9, 1999, respondent sent the estate a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing.
On March 3, 1999, respondent received the estate’s Request for a
Collection Due Process Hearing, Form 12153. At the section 6330
hearing (hearing), on April 28, 1999, the estate presented
evidence that it had sought to obtain a loan to pay the tax.
Between May 5, 1999, and June 15, 2000, the Appeals officer and
the estate’s attorneys had several telephone conferences to
discuss the estate’s continued efforts to secure a loan and
various other issues raised at the hearing.
IV. Denial of Abatement Request
On June 16, 1999, more than 1 year after respondent sent the
notice and demand, the estate requested an abatement of the
section 6651(a)(2) addition to tax (request for abatement). On
June 30, 1999, respondent denied the estate’s request and
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