John G. Goettee, Jr. and Marian Goettee - Page 32




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               Fish’s recommendations were approved on October 31, 1996,              
          and a notice of disallowance was issued to petitioners on                   
          November 13, 1996, setting forth the amounts shown supra under              
          “Allowed”, disallowing the balance of the claims, but not stating           
          the amounts disallowed.                                                     
          G.  Other Matters; Conclusions                                              
               At some point, probably in December 1996, possibly in                  
          January 1997, respondent returned to petitioners the $40,000 that           
          petitioners paid in connection with their offer in compromise.              
               Tax assessments in the amounts of $1,360 for 1979 and $87              
          for 1981 are not subject to the section 6621(c) rate.                       
               Respondent has overassessed interest in at least the amounts           
          of $108.33 for 1981 and $298.47 for 1982.                                   
               Respondent’s failure to abate interest for the period                  
          December 2, 1993, through October 26, 1994, was not an abuse of             
          discretion.                                                                 
               Respondent’s failure to abate interest for the period                  
          December 14, 1994, through January 25, 1995, was not an abuse of            
          discretion.                                                                 
               Respondent’s failure to abate interest for the period                  
          January 26 through February 24, 1995, was an abuse of discretion.           
          Respondent concedes that there should be an abatement of interest           
          for the period February 25 through April 24, 1995.                          








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