John G. Goettee, Jr. and Marian Goettee - Page 25




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               Additional assessments, abatements, and credits after August           
          18, 1995, resulted in balances shown in table 4, payments of                
          which by petitioners were posted on December 11, 1996 (as to                
          1978, 1981, and 1982), and December 24, 1996 (as to 1979).                  
                                       Table 4                                        
          Penalty for                                                                 
          Year        Interest        Late Payments        Payment                    
          1978      $65,316.82          $73.03         $65,389.85                     
          1979      36,519.51           123.11         36,642.62                      
          1981      4,974.51            5.53           4,980.04                       
          1982      13,952.46           21.49          13,973.95                      
               Petitioners have paid all tax and interest assessed for                
          1979, 1981, and 1982; no additional tax or interest needs to be             
          assessed.                                                                   
          F.  The Abatement Process                                                   
               At or about the time of petitioners’ September 5, 1995,                
          letter, petitioners also wrote to their Congressman.  On                    
          September 8, 1995, petitioners’ Congressman wrote to respondent.            
               On September 22, 1995, in response to petitioners’ September           
          5 letter, respondent thanked petitioners for their payment of               
          $33,046.02 (the sums of the amounts on table 2, supra) and told             
          them that (1) respondent had not yet gathered all of the                    
          information necessary to give to petitioners a complete answer to           
          their abatement request letter, (2) respondent would contact                
          petitioners within 30 days to inform them about the status of               








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