- 10 - 2. Whether Petitioner Is Entitled to Abatement of Interest as a Result of (a) Respondent’s Levy on Petitioner’s Keogh Account; (b) Respondent’s Initial Crediting of the Levied Funds to 1985; or (c) Petitioner’s Agreement To Extend the Time To Assess Tax Petitioner seeks abatement of interest related to his 1989 tax year on the grounds that respondent allegedly improperly levied his Keogh account, and applied the funds levied from his Keogh account to his 1985 year before posting them to his 1989 year. We disagree. Respondent’s levy resulted in collection of tax, which reduced the amount of interest that would otherwise have accrued. No interest accrued because of the levy. Respondent credited the levied funds to petitioner’s 1985 tax year on October 13, 1993, but subtracted the levied amount and credited those funds to petitioner’s 1989 tax year, also on October 13, 1993. No additional interest accrued for 1989 as a result of crediting the levied funds to petitioner’s 1985 tax year. On October 15, 1998, at respondent’s request, petitioner signed a tax collection waiver for assessments which extended to December 31, 2000, the time to collect petitioner’s tax liabilities assessed on December 19, 1988, for tax year 1987, and on November 19, 1990, for tax year 1989. However, no additional interest accrued for 1989 as a result of petitioner’s signing the tax collection waiver. 5(...continued) (2) in a subsequent refund case in a refund forum.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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