David A. Brown - Page 3

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          Revenue Code as amended.  The decision to be entered is not                 
          reviewable by any other court, and this opinion should not be               
          cited as authority.                                                         
               In the previous opinion we remanded this case “for further             
          proceedings as to 1996 concerning the issue of an abatement of              
          interest and particularly whether petitioner made a payment of              
          the amount due in accordance with instructions from respondent’s            
          representative (Ms. Ogle).”  We ordered that respondent offer               
          petitioner an administrative hearing and further ordered that               
          each party submit a status report.  The parties have complied               
          with our order.                                                             
               In his status report petitioner states his position as                 
          follows:                                                                    
               A final payment due was made in 1999 based on an amount                
               given to me by the Taxpayer Advocate Office (a                         
               representative of the IRS).  The records of that office                
               are no longer available to substantiate my claim.  The                 
               IRS has substantially inflated the interest amount of                  
               which I seek abatement, before and after final payment                 
               in 1999.  It is the IRS failed process, which has                      
               contributed to the prolonged nature of this case.                      
               In support of this position petitioner explains that he met            
          with Settlement Officer Elissa Sharp and Robert A. Rosenblatt,              
          Appeals Team Manager.1  Petitioner complains that Ms. Sharp was             
          “unprofessional,” that he had to request Mr. Rosenblatt’s                   




               1  Petitioner described them as “Appeals Officers”.                    





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