John G. Goettee, Jr. and Marian Goettee - Page 29




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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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