John G. Goettee, Jr. and Marian Goettee - Page 26

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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               
               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            
               You will receive a notice of the balance due within two to             
               three weeks.                                                           

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