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Petitioners requested abatement of their 1982 and 1983
liabilities and abatement of penalties and interest relating to
all of their outstanding tax liabilities. Petitioners further
contended that the proposed collection would be unduly intrusive.
Salinger did not consider any of petitioners’ claims regarding
additional deductions relating to 1982.
On October 22, 1992, and December 7, 1993, petitioners filed
bankruptcy petitions that were discharged on December 17, 1993,
and July 13, 1994, respectively. By letter dated October 18,
2001, respondent explained how the filing of petitioners’
bankruptcy petitions and execution of Form 900 extended the
collection period.
In a letter dated November 9, 2001, petitioners contended
that the collection period relating to their 1982 and 1983
liabilities began to run on September 17 and November 5, 1984,
(i.e., the dates the respective returns were filed), petitioners’
bankruptcy filings extended the collection period by only 180
days, and Form 900 was executed outside the collection period.
Petitioners further asserted that the correct amount of their
liability had yet to be determined. In a letter dated November
13, 2001, Salinger rejected petitioners’ contentions and urged
petitioners to provide the requested financial information.
Salinger also contended the following: (1) Respondent correctly
calculated penalties and interest relating to 1982, posted
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