Robert L. Stewart - Page 8

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          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 applied             












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