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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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