- 32 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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