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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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Last modified: May 25, 2011