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during which respondent held the $40,000 that accompanied
petitioners’ offer in compromise.
Firstly, petitioners paid the $40,000 in connection with an
offer in compromise to settle the dispute as to their interest
liabilities for 1978, 1979, 1981, and 1982. About $65,000 of the
then-disputed interest, more than half the total, was interest
for 1978, a year as to which we do not have jurisdiction to grant
relief. Indeed, petitioners’ $40,000 offer was less than two-
thirds of the 1978 interest alone. Neither side has suggested
any way to apportion or allocate the $40,000 offer between 1978
on the one hand and 1979, 1981, and 1982 on the other hand.
Petitioners did not make any such allocation in their offer in
compromise. An allocation first to the interest on the oldest
year’s liability would not leave anything for any of the years as
to which we could grant relief.
Secondly, respondent abated interest on the entire
liabilities for the period October 4, 1995, through September 20,
1996. Supra table 5 and associated text. Respondent held
petitioners’ $40,000 from May 1996 until about the end of that
year. Thus, there already is an abatement of interest on the
whole debt for somewhat more than half of the period during which
respondent held petitioners’ $40,000.
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