George N. and Maggie Ahmaogak - Page 9

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          the Appeals officer observes that the $3,506 payment that                   
          respondent applied to 1989 pursuant to petitioners’ designation             
          is the amount agreed upon in settlement of petitioners’ 1990                
          Federal income tax liability.  According to the Appeals officer,            
          “it might have been * * * [petitioners’] intent to file an                  
          interest abatement request with respect to TY1990 rather than               
          TY1989".  Neither party commented on this observation in any                
          document submitted in this proceeding.                                      
                                     Discussion                                       
               It appears to us that the observation of the Appeals officer           
          is well made.  Nevertheless, taking our lead from the parties, we           
          ignore the possibility that this proceeding results from a                  
          mistaken reference to 1989 and consider whether respondent’s                
          failure to abate some of the interest applicable to petitioners’            
          Federal income tax for that year is an abuse of discretion.  For            
          the following reasons, we hold that it is not.                              
               In general, interest on a Federal income tax liability,                
          including a deficiency, begins to accrue on the due date of the             
          return and continues to accrue, compounding daily, until payment            
          is made.  See secs. 6601(a), 6622.                                          
               The Commissioner has the authority to abate the assessment             
          of interest on a deficiency or payment of income tax if the                 
          accrual of such interest is attributable to an error or delay by            
          an official or employee of the Internal Revenue Service in                  






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