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to discuss petitioners’ case. On October 27, 1998, Agent
McIntosh again met with Manager Laverty to discuss petitioners’
case. On October 28, 1998, Manager Laverty had a telephone
conference with petitioner Raymond Jean. On October 29, 1998,
petitioner Raymond Jean had a telephone conference with
Examination Branch Chief Keith Zepeda concerning petitioners’
audit. On October 30, 1998, Manager Laverty sent identical
letters addressed to each petitioner requesting a final
conference with herself and Agent McIntosh and for petitioners to
bring with them “100%” of the documentation supporting their
claim to the NOL. The conference was scheduled for, and attended
by the parties on, December 1, 1998. Petitioners failed to
provide the documentation requested.
Eventually, respondent and petitioners resolved the issues
that arose during the examination. On December 24, 1999,
petitioners filed with respondent Form 843, Claim for Refund and
Request for Abatement. On February 9, 2000, respondent issued a
final determination letter disallowing petitioners’ claim for
abatement of interest for the aforesaid periods.
OPINION
Pursuant to section 6404(e)(1), the Secretary may abate all
or any part of an assessment of interest on any deficiency or
payment of tax if either: (A) The deficiency is attributable, in
whole or in part, “to any error or delay by an officer or
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