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25, 1995, Number CP 503 shows $15,134.78. Would you
please explain the difference.
It is also my understanding that Mrs. Goldin paid the
actual tax billed by IRS during the first week of
September 1995.
I look forward to your explanation and appreciate your
assistance in clearing her file.
On December 4, 1995, respondent assessed an accuracy-related
penalty for substantial valuation misstatement under section
6662(e) of $1,135 for 1983.
On January 16, 1996, in response to a notice that petitioner
owed $2,284.88 in interest for 1983, petitioner wrote to
respondent as follows:
I have no idea what this is all about. No Notice 680
was enclosed. I have already been assessed & paid
additional tax & penalty of almost $23,000. What else can
you possibly want to extract from me & my dead husband? I
am enclosing a copy of all the actions taken on this account
since 1983. Surely this latest assessment is redundant & in
error. Thank you.
On January 22, 1996, petitioner paid interest of $15,592.79
for 1983 and $3,517.20 for 1984.
On February 5, 1996, Kohl sent a letter (Kohl’s February 5,
1996, letter) to respondent which reads as follows:
I have discovered, after a careful and detailed
review of your audit findings and billings of
additional tax and interest, that the additional tax
due was computed without the benefit of income
averaging. This resulted in a reduction of tax in the
amount of $2,970.
Tax computed by IRS $ 7,565
Tax computed by Income Averaging 4,595
Tax reduction $ 2,970
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