Thomas Frederick Dadian and Lois Ann Dadian - Page 6

                                        - 6 -                                         
               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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