D. Jean Bartelma and Dan F. Bartelma - Page 7

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          dated April 24, 2001.  These errors had subsequently been                   
          corrected on Dan and Jean’s December 10, 2001, tax bill and on              
          James and Cynthia’s January 7, 2002, tax bill.  Welp determined             
          that petitioners should be granted an interest abatement for the            
          period between April 24, 2001, and January 7, 2002.  Therefore,             
          Dan and Jean received 28 extra days of interest abatement because           
          they received their tax bill on December 10, 2001, but were                 
          allowed interest abatement through January 7, 2002.  The interest           
          abatement was reduced by the amount of abatement previously                 
          allowed for the period between August 17 and October 31, 2001.              
          As a result, Dan and Jean received an abatement of $23.42, and              
          James and Cynthia received an abatement of $75.44.  These amounts           
          were reflected in the notices of Partial Allowance--Final                   
          Determination sent to petitioners on October 22, 2002.                      
          Petitioners paid the disputed balances on December 10, 2002, and            
          filed petitions with the Court on December 16, 2002.  The amounts           
          in dispute are $1,204.08 for Dan and Jean and $5,124.07 for James           
          and Cynthia.                                                                
               Under section 6404(e)(1), the Commissioner may abate the               
          assessment of interest on any deficiency if the interest is                 
          attributable to an error or delay by an officer or employee of              
          the IRS (acting in his official capacity) in performing a                   
          ministerial act.  (Amendments to section 6404(e) in 1996 do not             

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