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suspended the implementation of the basis of settlement for the
TEFRA Swanton programs until the litigation phase of the pre-
TEFRA cases had concluded.
Asher’s tax matters partner (TMP) signed a closing
agreement with respect to Asher’s tax liabilities on July 9,
1997. It was countersigned by respondent on December 10, 1998.
On August 20, 1999, respondent sent petitioner a letter
explaining that the examination of Wilshire had been completed.
Respondent also sent petitioner Form 4549A-CG, Income Tax
Examination Changes (notice of adjustment), notifying petitioner
that his 1983 taxable income had been adjusted by $12,542 and his
1984 income had been adjusted by $718. These adjustments
resulted in deficiencies of $5,226 for 1983 and $773 for 1984.
In October 1999, petitioner paid the deficiencies. On November
1, 1999, respondent assessed petitioner’s deficiencies and
interest and issued petitioner a letter stating that petitioner
owed $23,915.94 of section 6621(c) interest for 1983. Also on
November 1, 1999, respondent issued petitioner a letter stating
that he owed $2,198.97 of section 6621(c) interest for 1984.
On November 8, 1999, petitioner filed Form 843, Claim for
Refund and Request for Abatement, requesting abatement of the
interest that had accrued from 1983 to 2000. On February 19,
2002, respondent issued a letter entitled “Partial Allowance-
Final Determination” (notice of determination) to petitioner. In
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