-8- assessed interest on a deficiency only for any period “after the Internal Revenue Service has contacted the taxpayer in writing with respect to such deficiency”. Sec. 6404(e)(1). Respondent contacted petitioner in writing with respect to petitioner’s 1990 income tax deficiency on January 15, 1996, when he sent to petitioner the first erroneous monthly statement. Respondent then corrected his mistake on October 25, 1999. Respondent’s denial of petitioner’s claim to abate interest is supported by the overly broad scope of petitioner’s claims. See Donovan v. Commissioner, T.C. Memo. 2000-220. Petitioner argues that he is entitled to the abatement of interest that accrued on his 1990 tax deficiency before January 15, 1996, and after October 25, 1999, because: (1) Respondent erred in computing his 1990 tax liability when he entered into an installment agreement in 1996; (2) his installment payments should have been larger or the period of his installment agreement should have been longer; (3) respondent erroneously released a tax lien against his property; (4) respondent gave him an incorrect payoff balance and statement of account; and (5) a payment made on his 1992 tax liability should have been appliedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011