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regarding their 1993 and 1994 tax liabilities. By that time,
petitioners had made additional payments of $20,000 in respect of
their 1993 tax liability and $500 in respect of their 1994 tax
liability. Respondent rejected petitioners’ initial offer in
compromise in March 1996. During the period from March 1996 to
October 1998, petitioners submitted several additional and
revised offers in compromise, none of which respondent accepted.1
During that same period, petitioners made aggregate payments of
$4,500 in respect of their 1993 tax liability and received an
additional $1,476 credit with respect thereto.
Petitioners’ Requests for Abatement
In a letter addressed to Revenue Officer Melvin Chappell
dated September 13, 1997, petitioners requested abatement of
additions to tax asserted by respondent with respect to their
1993 and 1994 taxable years.
On October 8, 1998, petitioners filed separate Forms 843,
Claim for Refund and Request for Abatement, with respect to their
1993 and 1994 taxable years. On the Forms 843, petitioners
requested abatement of both interest and additions to tax. In a
letter submitted with the Forms 843, petitioners claimed that
such interest and additions to tax resulted from unreasonable
1 Petitioners maintain that they submitted a total of five
offers in compromise. Respondent maintains that petitioners
submitted three offers in compromise and two revised or amended
offers. For the sake of clarity, we treat petitioners’
submissions as five separate offers in compromise.
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Last modified: May 25, 2011