William and Penny Landvogt - Page 7

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          Claim for Refund and Request for Abatement, on September 10,                
          2001, requesting that respondent abate the entire amount of                 
          interest assessed by respondent on July 31, 2001.3  In a letter             
          dated December 20, 2001, respondent disallowed petitioners’ claim           
          for interest abatement, which decision petitioners promptly                 
          appealed in a letter to respondent dated January 7, 2002.                   
               On July 3, 2002, respondent issued to petitioners a notice             
          of final determination denying their request for abatement of               
          interest for 1992, 1993, and 1994.  In the notice of final                  
          determination, respondent found that there were no errors or                
          delays during the period “from April 15, 1993 to the present”               
          relating to the performance of a ministerial act.                           
               On July 19, 2002, petitioners filed a timely, but imperfect,           
          petition for review of respondent’s failure to abate interest.              
          In petitioners’ amended petition, filed on August 20, 2002,                 
          petitioners alleged:  (1) “IRS did not correctly apply the law in           
          regard to assessment of tax”; (2) “There was an unnecessary delay           
          in assessing the tax due to IRS management failures”; and (3)               
          “The original assessment was not correct and not corrected until            
          2001 by IRS attorney James Schacht”.                                        

               3The record indicates that petitioners requested on their              
          Form 843 that respondent abate the deficiencies in their income             
          taxes together with the interest assessed by respondent on July             
          31, 2001.                                                                   

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