- 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
Last modified: May 25, 2011