- 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