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that interest had been paid as of March 26, 1993. By letter
dated January 24, 2001, respondent notified petitioners that
$7.14 of interest that accrued from March 26, 1993, to July 14,
2000, would be abated but denied petitioners’ request for
abatement of interest that had accrued before March 26, 1993. By
letter dated February 23, 2001, petitioners requested that
respondent’s Appeals Office reconsider the portion of their
abatement claim that had been denied. In this letter,
petitioners identify “a number of delays”, one of which
erroneously lists the date of the revenue agent’s report as
December 16, 1992, when, in fact, as noted above, the report was
issued on December 16, 1991. The letter goes on to allege that
petitioners’ abatement claim (received by respondent on June 27,
2000) “was filed * * * shortly after assessment of the interest
in this case”. As noted, with the exception of $8.61, all of the
interest that had previously accrued was assessed and paid as of
March 26, 1993. Petitioners’ use of the term “shortly” is
expansive, to say the least.
The Appeals officer assigned to the matter prepared a
detailed chronology of events relevant to the determination of
petitioners’ 1989 Federal income tax liability. Petitioners
apparently were provided a copy of this chronology before
February 23, 2001, as their letter to respondent on that date
makes reference to it. In a note included within the chronology
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