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Petitioner presents in her claim alternative arguments as to
why interest on the 1994 tax deficiency should be abated. These
arguments are lack of knowledge that interest was accruing and
inability to pay. Petitioner’s arguments fail on the basis of
the record.
Lack of Knowledge
Petitioner argues that she thought that she needed to pay
only the deficiency and penalty determined in the decision
document and that she did not know to look at her nonmaster file
account to know that there was interest assessed. Interest on a
Federal income tax liability generally begins to accrue from the
last date prescribed for payment of that tax and continues to
accrue, compounding daily, until payment is made. See secs.
6601(a), 6622(a). Petitioner, a tax return preparer by
profession, admitted at trial that she knew that interest accrues
on unpaid taxes. Therefore, petitioner’s lack-of-knowledge
argument must fail.
Petitioner’s nonmaster file transcript reports that
petitioner received four notices regarding the balances in her
account, including accrued interest. The Appeals officer
testified that, even when petitioner’s account was in 53 status,
petitioner would have still received an annual notice reflecting
the 1994 balance due. Petitioner’s claim that she had no
knowledge of the accrued interest fails on the basis of the
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