Thomas Corson - Page 4

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          the partnership litigation.                                                 
               After the partnership litigation concluded, in a letter                
          dated September 14, 1999, respondent explained to petitioner that           
          respondent had adjusted petitioner’s 1983 income tax return as              
          described in an enclosed Form 4549A-CG, Income Tax Examination              
          Changes.  The Form 4549A-CG indicated that petitioner owed                  
          additional income tax for 1983 attributable to his involvement in           
          Boulder in the amount of $766 and interest in the amount of                 
          $2,523.04.3  On November 29, 1999, respondent assessed the                  
          additional income tax and accrued interest.                                 
               Believing that he had settled all taxable years other than             
          1981 when he signed the settlement agreements, petitioner first             
          attempted to resolve the matter with the Taxpayer Advocate’s                
          Office in January 2000.  Then, on August 31, 2000, petitioner               
          submitted to respondent a Form 843, Claim for Refund and Request            
          for Abatement, requesting an abatement of interest for the                  
          taxable year 1983.  In a letter to Appeals Officer Paul Sivick              
          dated July 31, 2001 (July 31 letter), petitioner argued that he             
          had settled all taxable years other than 1981.  As evidence,                
          petitioner attached copies of the settlement agreements.                    
               In a letter dated September 18, 2001, Appeals Officer Sivick           
          addressed the arguments in petitioner’s July 31 letter.                     
          Responding to petitioner’s argument that he had settled all                 

               3The interest was computed to Oct. 9, 1999.                            





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