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their case, and (3) they need not take any further action with
respect to their request.
On September 25, 1995, respondent wrote to petitioners’
Congressman, stating as follows:
Dr. Goettee paid the assessed tax and should now submit his
request for abatement on Form 843. His request should be
mailed to Internal Revenue Service, Philadelphia,
Pennsylvania 19020. We have enclosed a Form 843 for his
convenience.
On October 6, 1995, petitioners received from respondent (an
office in Bensalem, Pennsylvania) a notice of deficiency for
1983. Respondent enclosed a Form 843 (Claim for Refund and
Request for Abatement) with the 1983 notice of deficiency.
On October 9, 1995, petitioners wrote to the Cincinnati
office, asking respondent to deal with all their tax matters from
one office, because it “is completely overwhelming for us” to
deal with two different offices about tax disputes arising from
the same partnership. Petitioners enclosed a Form 843 requesting
(1) an abatement of interest on 1983 taxes and (2) an abatement
of 1983 penalties under section 6653.
On October 20, 1995, respondent further replied to
petitioners’ September 5 letter, in pertinent part as follows:
You must file Form 843 for each year you are requesting an
abatement of interest. We have enclosed Forms 843 for your
convenience.
You will receive a notice of the balance due within two to
three weeks.
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