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Please provide the information by Nov. 18, 1995. We have
enclosed an envelope for your convenience.
On October 23, 1995, petitioners replied to respondent’s
October 20 letter. Evidently, the forms respondent had enclosed
with the October 20 letter dealt with 1994 household employment
taxes. Petitioners used, instead, copies of the Form 843 that
respondent had included in the October 6 letter. Petitioners
complied with the October 20 letter instructions by enclosing a
separate Form 843 for each of the years 1978, 1979, 1981, and
1982, in the amounts shown in table 3, supra.
On February 5, 1996, respondent proposed to disallow
petitioners’ abatement request in full.7 Respondent gave the
following reasons to support this proposed decision: (1) The
time petitioners’ case was before this Court does not constitute
a delay in the performance of a ministerial act, and (2) the
delay in settling petitioners’ case was not attributable to
respondent.
Petitioners appealed respondent’s proposed disallowance. On
March 21, 1996, Samuel E. Fish, Jr. (hereinafter sometimes
referred to as Fish), an Appeals officer in respondent’s
Baltimore, Maryland, Appeals Office (hereinafter sometimes
7 The amounts listed in the Feb. 5, 1996, letter are
slightly greater than the amounts claimed in petitioners’ Forms
843. We assume that the difference, almost 2.2 percent for each
year, represents the additional interest that had accrued after
the Aug. 18, 1995, assessment. Supra table 3.
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