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sound basis in fact or law. Woodral v. Commissioner, 112 T.C.
19, 23 (1999).
In view of the partial allowance of petitioner’s claim for
abatement, it is necessary to address only those periods in which
interest accrued between April 15, 1984, and May 8, 1992, and
subsequent to April 15, 1999. An understanding of the earlier
period, however, requires an explanation of other events
occurring during the period for which abatement was allowed by
the Appeals office. The period from April 15, 1999, to
September 30, 2001, is explained by the chronology in our
findings of fact, and petitioner has not argued that unnecessary
or unexplained delay occurred during that period.
Petitioner is concerned primarily by the failure of the IRS
to notify her and her husband of the deficiencies in tax for 1983
and 1984 during the time that TEFRA proceedings were pursued
through the TMPs of Jackson and Wilshire West. In that regard,
it is necessary to understand the parameters of litigation over
Swanton coal shelter programs. Much of the background was
explained by the testimony of Moira Sullivan, an attorney for the
IRS charged with responsibility for the litigation. Documents
concerning the Swanton cases were lost as a result of the
destruction of the World Trade Center on September 11, 2001.
Other explanations are found in two opinions of this Court
rendered in Swanton coal program cases.
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