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notice sent to James and Cynthia C. Bartelma (Cynthia) determined
a deficiency of $27,457. These notices stated that, if
petitioners did not agree with the deficiency but wished to stop
the running of interest, they should make a cash bond and mail it
to the Appeals officer. Dan and Jean filed their petition with
the Court on March 13, 2000, and James and Cynthia filed their
petition with the Court on March 3, 2000. They did not make a
cash bond to stop the running of interest. Those cases were
consolidated and settled, and decisions were entered on
October 26, 2000. The decisions resulted in deficiencies of
$10,760 against Dan and Jean and $14,396 against James and
Cynthia. Additionally, the decisions stated that “interest will
be assessed as provided by law on the deficiency due from the
petitioners.”
On March 8, 2001, interest was assessed against petitioners.
On April 24, 2001, McKenney, who had been reassigned to
petitioners’ cases, sent to petitioners letters estimating the
amount of tax petitioners would owe for 1995. Additionally,
petitioners were made aware of the interest that was accruing on
their deficiencies. In a letter dated April 26, 2001, Berger
requested that the IRS grant petitioners a 63-percent abatement
of interest on the deficiencies due to unreasonable IRS delays.
There was no Form 843, Claim for Refund and Request for
Abatement, attached to this letter. In letters dated May 3 and
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Last modified: May 25, 2011