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$22,773 on November 16, 1998, $29,485 on January 11, 1999, and
$3,063 on October 5, 1998, for 1982, 1983, and 1984,
respectively. Petitioner failed fully to pay the Federal income
tax liabilities for 1982 through 1984.
Request for Abatement of Interest
On December 17, 1998, C. Edmonds Allen (Allen) sent a letter
to Nancy L. Jones at the IRS Kansas City Service Center
requesting a correction in the calculation of petitioner’s
interest. The letter erroneously claimed that the TEFRA
partnership settlement stated that the partnerships were not
subject to the tax-motivated penalty under section 6621(c).
Further, the letter argued that interest was overassessed for
1982. The letter suggested that Sullivan be contacted for
documentation and verification of the settlement. Sullivan was
contacted and confirmed that section 6621(c) interest applied.
On January 12, 1999, Tax Examining Assistant Fred Fuqua
(Fuqua) responded in a letter to petitioner stating that Allen
was not an authorized representative to handle petitioner’s tax
matters. On February 4, 1999, Fuqua sent to petitioner an
additional letter notifying petitioner that interest based on
tax-motivated transactions was correct but that the amount of the
interest for 1982 would be adjusted because it was overassessed.
On July 12, 1999, the IRS sent to petitioner a Final Notice
of Intent to Levy and Notice of Your Right to a Hearing. On
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