Thomas and Julia Bo - Page 16

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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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