Lawrence S. and Myrna Ahmaogak - Page 6

                                        - 6 -                                         
               which would have substantially affected the treatment                  
               of specific deductions.  Accordingly, the Service                      
               postponed consideration of these matters.  Further, a                  
               death in the family of our legal counsel resulted in an                
               additional delay in consideration of our case.  In                     
               light of the ministerial delays, and as well as our                    
               reliance on the actions of Congress, the failure to                    
               abate interest in our circumstances would constitute                   
               grossly unfair treatment and impose on us an undue                     
               hardship.                                                              
                                                                                     
          On the abatement claims, petitioners requested abatement of                 
          interest as follows:                                                        
               Year              Period               Approximate Amount              
               1986        02/02/1989 — 10/1999            $13,300                    
               1987        02/02/1989 — 10/1999            25,000                     
               1988        12/16/1991 — 10/1999            16,700                     
               1989        06/10/1991 — 10/1999            10,000                     
               1991        09/13/1993 — 10/1999            2,500                      
               By letter dated January 24, 2001, respondent notified                  
          petitioner that for 1986 and 1987, $295.43 of interest that                 
          accrued from June 8 to July 3, 1989, would be abated, but                   
          otherwise denied each of petitioners’ requests for abatement of             
          interest.  The reason for the partial allowance has not been                
          provided.  By letter dated February 23, 2001, petitioners                   
          requested that respondent’s Appeals Office reconsider the portion           
          of the abatement claims that had been denied.  On February 28,              
          2001, respondent issued a notice of final determination in which            
          respondent refused, with the exception previously noted, to abate           







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011