- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011