- 8 - December 4, 2002. The Form 843 requested abatement of interest and penalty for the year 1998 in the amount of $2,026.91. Petitioner’s request was assigned to Appeals Officer Michael Bibb, and on April 24, 2003, an Appeals conference was held to discuss petitioner’s Form 843. On May 22, 2003, respondent issued a Full Disallowance--Final Determination, denying petitioner’s request for abatement. Petitioner’s petition seeking review of respondent’s failure to abate interest under section 6404 was filed with this Court on June 30, 2003. The petition claims that respondent’s determination is based on the following error: “The Petitioner and the Internal Revenue Service agreed upon and reached a full and final settlement of all disputed issues, as a consequence of which the Internal Revenue Service’s attempts to collect additional interest are erroneous.” OPINION I. General Rules A. Section 6404 Generally Section 6404(e) provides, in relevant part, as follows: SEC. 6404(e). Abatement of Interest Attributable to Unreasonable Errors and Delays by Internal Revenue Service.-- (1) In general.-- In the case of any assessment of interest on-- (A) any deficiency attributable in whole or in part to any unreasonable error or delay by an officer or employee of the InternalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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