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On February 9, 2000, respondent sent petitioners a letter
explaining that the examination of Redwood had been completed.
There is no evidence in the record that respondent contacted
petitioners personally before this date regarding their 1984
taxable year. With the February 9, 2000, letter, respondent also
sent petitioners Form 4549A-CG, Income Tax Examination Changes
(notice of adjustment), notifying petitioners that their 1984
taxable income had been adjusted by $10,219. The adjustment
resulted in a deficiency of $3,912 for 1984. The notice of
adjustment also stated that petitioners owed $16,390.95 of
section 6621(c) interest. Respondent assessed the deficiency and
the interest on May 29, 2000. On June 7, 2000, petitioners paid
$20,302.95 toward their assessed liabilities.6
On December 18, 2000, petitioners filed Form 843, Claim for
Refund and Request for Abatement, requesting abatement of the
interest that had accrued from 1986 to 2000. On November 29,
2001, respondent issued a notice of determination (notice) to
petitioners, denying in full their request for interest
abatement. The notice states that the Appeals officer did not
find any errors or delays on respondent’s part to merit the
abatement of interest. The notice also states that respondent
6 Although the parties have stipulated that petitioners made
a $20,302.95 payment on June 7, 2003, the Form 4340, Certificate
of Assessments Payments and Other Specified Matters, included in
the record as Exhibit 7-J shows that the payment was credited to
petitioners’ account on June 7, 2000.
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