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1995, the Louisville office sent the administrative file and a
copy of the decision document to the Cincinnati office. The
Cincinnati office received this material on June 5, 1995.
As of June 1, 1995, the Louisville office recorded a total
of 13 hours on petitioners’ deficiency case.
Petitioners’ deficiency case never was set for trial.
E. Assessments; Payments
A Form 2859, Request for Quick or Prompt Assessment, for
1978 was prepared and approved on August 16, 1995. On August 18,
1995, respondent assessed the deficiencies shown supra in table 2
and interest in the amounts shown in table 3.
Table 3
Year Interest
1978 $65,336.10
1979 36,456.54
1981 4,689.52
1982 13,243.89
Bills for the assessed amounts were sent to petitioners on the
same day. The first time petitioners were notified of the
amounts of interest was when they received these bills.
On September 5, 1995, petitioners paid the entire amounts
shown supra on table 2 (deficiencies and additions to tax) for
1978, 1979, 1981, and 1982. These payments were posted to
petitioners’ account as of September 8, 1995. In their letter
enclosing these payments, petitioners requested “an abatement of
the interest.” See supra table 3.
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