- 31 - July 31, 1996, the effective date for the relevant provisions in TBOR 2. Fish advised petitioners to do this to protect their right to petition the Tax Court to review the Commissioner’s decision about petitioners’ abatement requests. On October 3, 1996, petitioners submitted new Forms 843. On October 25, 1996, Fish recommended that (1) interest should be abated for the period October 4, 1995, through September 20, 1996, because for that period “taxpayers were continually given incorrect advise [sic] and subject to the processing timeframes of the ill advised offer and interest abatement claims[, and]” (2) interest should not be abated for any period before petitioners paid the taxes because-- There were no ministerial or managerial acts which contributed to errors or delays, which were not part of the tax court/shelter process. The taxpayers were offered opportunities to resolve the matter in earlier years, as well as advised that a posted cash bond would suspend the accrual of interest. Fish’s analysis presented the dollar effects of his recommendations on petitioners’ interest abatement claims as shown in table 5. Table 5 Year Claimed Disallowed Allowed 1978 $66,763 $65,439 $1,324 1979 37,252 36,508 744 1981 4,792 4,688 104 1982 13,533 13,143 390 1983 4,270 4,129 141Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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