- 9 - 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 inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011