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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 Internal
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