-5-
On October 25, 1999, respondent assessed against petitioner
an addition to tax of $828.30 under section 6651(a). The same
day respondent sent to petitioner a notice stating that
respondent had changed his 1990 account to “correct
[petitioner’s] penalty charge and interest charges.” That
statement showed the addition to tax of $828.30 and interest due
of $3,414.37. Petitioner immediately sent a fax to Revenue
Officer Curtis Rowe. Attached to that fax were copies of monthly
statements that petitioner previously received from respondent.
Those statements were dated March 19, 1997, June 16, 1999, July
14, 1999, and August 18, 1999, respectively. In addition,
petitioner attached a copy of his statement of account dated
August 9, 1999. The monthly statements and petitioner’s
statement of account, which petitioner sent to the Revenue
officer, did not show any interest or penalties/additions to tax
owed by petitioner.
Respondent treated petitioner’s October 25, 1999, fax as an
informal request for interest abatement. On November 8, 1999,
respondent denied petitioner’s interest abatement request.
On November 17, 1999, petitioner appealed respondent’s
determination not to abate all of the interest and additions to
tax assessed against him with respect to his 1990 income tax
liability.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011