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and May 3, 1999, respondent abated the late payment penalty of
$222, $111, and $3,162 respectively.
The Taxpayer Advocate also determined petitioner was
entitled to abatement of the interest assessed for the period
April 17, 1998, through April 30, 1999, because of delays caused
by the Problem Resolution Office. Respondent abated interest of
$297, $149, and $1,012 on April 19, April 26, and May 3, 1999,
respectively.
On January 21, 2001, petitioner filed Form 843, Claim for
Refund and Request for Abatement, requesting that respondent
abate all interest and all penalties associated with petitioner’s
tax liability for 1996. On July 13, 2001, respondent denied
petitioner’s request for the abatement of interest for the period
April 15, 1997, through April 16, 1998, and for the period May 1,
1999, to January 21, 2001.
On May 7, 2002, respondent issued to petitioner a Full
Disallowance--Final Determination for interest abatement for the
periods April 15, 1997, to April 16, 1998, and May 1, 1999, to
the present.
On September 11, 2002, petitioner filed a Petition for
Review of Failure to Abate Interest Under Code Section 6404,
which did not comply with the requirements of Rule 281(b). By
order of the Court, petitioner was given until October 24, 2002,
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Last modified: May 25, 2011