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of $895.84 with respect to the TFRP.5 On April 17, 2001, the
claim for refund was denied by the IRS. On April 23, 2001,
petitioners filed additional Forms 843 with respect to their
income taxes for 1993, 1994, and 1995. The Forms 843 were
treated as requests for abatement of interest on petitioners’
income taxes. On May 3, 2001, respondent denied petitioners’
claims for interest abatement for 1993, 1994, and 1995. On May
30, 2001, petitioners requested review by the IRS Appeals Office
of the denial of interest abatement. On December 19, 2001, the
IRS Appeals officer sent a final determination letter denying
petitioners’ claim for interest abatement for 1993, 1994, and
1995.
OPINION
As a preliminary matter, we must decide whether an agreement
to compromise petitioners’ liabilities was reached between
petitioner and the ACS employee. If we find that a valid
compromise existed, then it appears that petitioners’ liabilities
should have been extinguished upon their final payment on July
22, 1999. If we find that no compromise existed, we must decide
whether respondent abused his discretion in refusing to abate
interest on petitioners’ income tax liabilities.
5 The $895.84 represented the portion of the July 22, 1999,
payment that exceeded the $450 that petitioners’ 35th and 36th
installment payments would have totaled.
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