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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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