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As you present your case to the Appeals Officer, you may
want to mention the current change in the law and ask if the
concept can be applied to your case. It may help.
I hope your efforts are successful.
On July 30, 1996, Congress enacted the Taxpayer Bill of
Rights 2 (TBOR 2), Pub. L. 104-168, 110 Stat. 1452. TBOR 2 sec.
302(a), 110 Stat. at 1456, added section 6404(h)9 which gives to
this Court jurisdiction to review the Commissioner’s refusal to
abate interest under section 6404. TBOR 2 sec. 302(b), 110 Stat.
at 1458, provides that the amendments made by section 302(a)
apply “to requests for abatement after the date of the enactment
of” TBOR 2.
In lieu of the August 22 conference in the Baltimore office,
petitioners and Fish conferred by telephone on September 4, 1996.
At Fish’s request, on September 4, 1996, petitioners withdrew
their offer in compromise.
On September 13, 1996, Fish advised petitioners to prepare,
sign, and submit a new Form 843 for each year for which they
sought an abatement, so that the Forms 843 would be dated after
9 This provision was enacted as sec. 6404(g). Through a
series of amendments, former sec. 6404(g) was redesignated as
sec. 6404(i). Secs. 3305(a) and 3309(a) of the Internal Revenue
Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.
105-206, 112 Stat. 685, 743, 745. These amendments apply to
taxable years beginning after July 22, 1998. RRA 1998 sec.
3305(b), 112 Stat. at 743. Sec. 6404(i) then was redesignated as
sec. 6404(h) by sec. 112(d)(1)(B) of the Victims of Terrorism Tax
Relief Act of 2001, Pub. L. 107-134, 115 Stat. 2427, 2435. We
will refer to this subsection using its current designation, sec.
6404(h).
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