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result, petitioners agreed to a deficiency and a section 6662(a)
penalty totaling $3,506 for 1990.
On June 27, 2000, respondent received a payment of $3,5066
from petitioners designated to be applied to their 1989
liability. The transmittal letter with which the payment was
sent expressly references the year 1989. As a result of this
payment, interest of $15.75 ($8.61 plus $7.14 in interest that
had accrued from March 26, 1993, until July 14, 2000) was
assessed and paid, leaving petitioners’ account for that year
overpaid by $3,490.25.
At the time the above-referenced transmittal letter and
payment were received, respondent also received a Form 843, Claim
for Refund and Request for Abatement, from petitioners (the
abatement claim). Block 5 of the abatement claim is designated
“Explanation and additional claims.” Instructions following the
designation direct the taxpayer to “Explain why * * * this claim
should be allowed, and show computation of tax refund or
abatement of interest, penalty or addition to tax.” In the
designated area following these instructions on the abatement
claim, petitioners inserted the following:
6 This amount is erroneously referred to as “$4,506" in a
request for finding of fact included in respondent’s brief.
Petitioners, in their reply brief, agreed to respondent’s
erroneous request.
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Last modified: May 25, 2011