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On August 10, 1999, respondent determined petitioner and Mr.
Diarra’s account to be “currently-not-collectible” (53 status),
suspending the enforced collection. While a case is in 53
status, respondent sends a bill to the taxpayer once a year with
the balance on the master and nonmaster file accounts.
On April 15, 2001, and 2002, respondent applied petitioner’s
overpayments of $179 and $329 on her 2000 and 2001 tax returns,
respectively, to the 1994 tax deficiency and penalty. On March
18, 2002, petitioner made a payment of $2,146 to the 1994 tax
deficiency and penalty.
On November 12, 2001, respondent received from petitioner a
Form 843, Claim for Refund and Request for Abatement, in which
she requested that all accrued interest on the 1994 deficiency be
abated. Petitioner provided the following explanation as to why
she believed the claim should be allowed:
We are asking that this claim be allowed because the amount
owed is for interest and penalty that was the result of an
audit from 1995. After paying the tax obligation, we did
not realize that interest and penalty were accruing.
I contacted the Internal Revenue Service on several
occasions and was told that there was nothing outstanding
for tax year 1994. A reminder notice dated 08/20/2001 * * *
was received and we responded accordingly. After receiving
a reminder notice * * * dated September 3, 2001, I called
the Taxpayer Advocates [sic] office. The representative
explained to me why we received the reminder notices.
However, he said that our obligation was paid in full for
tax year 1994. The notice was for interest and penalty
only.
We have always had financial problems, but lately, we are
having serious financial problems. We are over extended as
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