- 6 - H. Respondent’s Communication With Petitioner in 1998 Regarding Respondent’s 1988 Reallocation of the $150,000 Payment On July 28, 1998, respondent told petitioner by letter that respondent had reallocated the $150,000 payment in proportion to the tax liability for 1986 of petitioner and his former wife and that, as a result, petitioner had unpaid tax liabilities for 1987, 1989, 1991, and 1992. The record does not show whether petitioner knew before July 28, 1998, that respondent had reallocated the $150,000 payment. I. Tax Collection Waiver and Respondent’s Final Determination On October 15, 1998, petitioner signed a Form 900, Tax Collection Waiver, in which he agreed to extend to December 31, 2000, the period for respondent to collect tax that respondent had assessed on December 19, 1988, for 1987, and on November 19, 1990, for 1989. On August 12, 1999, respondent issued a final determination denying petitioner’s claim to abate interest under section 6404(e). OPINION A. Background The Commissioner may abate part or all of the interest assessed on any deficiency or payment of income, gift, estate, and certain excise tax to the extent that any error or delay in payment is attributable to erroneous or dilatory performance of a ministerial act by an officer or employee of the Commissioner if:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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