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check for $40,000 with the May 29 Form 656.8 At respondent’s
request, on June 14, 1996, petitioners resubmitted their offer in
compromise using a newer version of Form 656. The June 14, 1996,
Form 656 provided that if respondent rejected petitioners’ offer,
then respondent would return the $40,000 without interest.
Respondent denied petitioners’ offer in compromise. On June
25, 1996, petitioners appealed the denial and asked for a
conference. In response, on August 7, 1996, Fish arranged for a
conference to be held on August 22, 1996, at the Baltimore
office.
On August 14, 1996, Becker responded to petitioners’
telephone call, as follows:
Thank you for your phone call regarding the status of your
case. I am glad to hear, it finally made it to the Appeals
Office in Baltimore.
As promised, attached are copies of pages from the “Taxpayer
Bill of Rights 2" relating to “Abatement of Interest and
Penalties”. Since this is a very new legislative change the
explanation is brief. It will take some time to develop
detailed guidelines.
8 Both sides’ briefs agree that petitioners paid this
$40,000 to respondent on May 15, 1996. As we have found (infra
text including table 5), respondent abated interest for the
period Oct. 4, 1995, through Sept. 20, 1996. Under these
circumstances, it does not appear to make a difference whether
the $40,000 was paid on May 29, 1996, as indicated in the
stipulated Form 656 of that date, or was paid on May 15, 1996, as
the parties agree on brief.
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