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May 4, 2001, McKenney stated that the requested interest
abatement was unreasonable. However, he did include the forms
and procedures necessary for petitioners to file a claim
properly. Additionally, McKenney recommended that petitioners
“pay at least the tax due and the amount of interest that you
reasonably believe you owe” in order to avoid additional interest
charges.
Petitioners filed Forms 843 on or about May 9, 2001,
requesting a 75-percent abatement of interest. On May 17, 2001,
petitioners’ voluntary payments of the tax deficiencies were
posted to their accounts. These payments included the tax
estimated as owed plus what petitioners asserted to be a
reasonable amount of interest, that being 25 percent of the
interest quoted in the April 24, 2001, letters from McKenney.
Petitioners had the ability to pay the entire amount due at the
time that they made their voluntary payments. However, they
believed that the amount of interest was unreasonable.
As of May 17, 2001, McKenney was also working on
petitioners’ 1993, 1994, and 1996 taxable years. Between May 17,
2001, and October 31, 2001, McKenney was unable to obtain Audit
Information Management System (AIMS) controls, which allow agents
to control their cases, for petitioners’ accounts. McKenney
determined that the process of obtaining AIMS controls should
have taken only 90 days. Therefore, on December 19, 2001, the
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