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failure to pay tax shown on the return under section 6651(a)(2)
for 1991-95, and abated interest on these additions to tax.
On March 28, 2003, petitioner telephoned the Taxpayer
Advocate Service office and spoke with Christy Elliott (Elliott).
Petitioner also wrote to Elliott on that date to confirm that he
told her that he had submitted Form 843 on October 9, 2002.
On March 31, 2003, respondent refunded the overpayments
resulting from the abatement of additions to tax and related
interest on March 21, 2003.
On April 16, 2003, respondent returned petitioners’ Form 843
because petitioners had not indicated why respondent should abate
interest for petitioners. On April 21, 2003, petitioner sent
Elliott copies of some of petitioners’ correspondence to and from
respondent.
On May 13, 2003, Diane Elm (Elm), accounts management,
respondent’s Ogden, Utah, Service Center, wrote to tell
petitioners that the Service Center had not completed the
processing necessary to resolve petitioners’ case. Elm said that
the IRS would contact petitioners within 60 days.
OPINION
A. Contentions of the Parties and Background
Petitioners contend that interest should be abated from
March 18, 1999 (when petitioners sent a letter to Davis stating
that their returns were wrong), through October 8, 2002, (when
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