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would remain in effect until petitioners’ taxes were paid in
full, their liability was satisfied through an offer in
compromise, or the statute of limitations prevented collection;
(b) she had transferred petitioners’ offer in compromise to the
Jacksonville office for processing; and (c) she was closing her
file on petitioners.
On September 5, 2002, Watson gave petitioners written payoff
figures for their taxes dues for 1991-95 if paid by September 16,
2002. On September 24, 2002, Watson gave petitioners written
payoff figures for their taxes due for their taxes due for 1991-
95 if paid by September 30, 2002.
4. Payment of Tax and Interest
Petitioners borrowed money using their residence as
collateral and, on October 8, 2002, paid their taxes due in full
as follows: $2,780.56 for 1991, $3,455.85 for 1992, $2,417.09
for 1993, $3,946.01 for 1994, and $991.77 for 1995. Petitioners
paid interest of $1,320.14 for 1991, $1,323.04 for 1992, $868.18
for 1993, $1,296.73 for 1994, and $288.69 for 1995.
Petitioners sent Wilkes a letter on October 9, 2002, and
enclosed a copy of a Form 843, Claim for Refund and Request for
Abatement, in which they requested abatement of interest that had
accrued for their 1991-95 tax years.
On March 21, 2003, respondent abated the additions to tax
for failure to timely file under section 6651(a)(1) and for
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