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information regarding the Brauns’ pension plans and investment
accounts rather than only petitioner’s 401(k) information.10 The
TA relayed this to Appeals, and Appeals mailed petitioner an
amended letter requesting the correct information. Petitioner
reported approximately $46,000 in investments as individual
retirement accounts.11
After reconsideration, Appeals affirmed respondent’s initial
determination rejecting petitioner’s offer in compromise for
$2,500. Appeals also rejected petitioner’s final offer to pay
the Brauns’ full tax liabilities for 1994 and 1997, excluding
interest.
Claim for Abatement
Because petitioner’s last offer in compromise amounted to
100 percent of the Brauns’ tax liability, petitioner’s claim
essentially took the form of an interest abatement claim.
Respondent therefore requested that petitioner submit a Form 843,
Claim for Refund and Request for Abatement, in connection with
his offer in compromise. In the interest abatement request,
petitioner alleged errors and undue delay in respondent’s
10The Brauns had previously submitted investment account
information in their Form 433-F on July 22, 1999.
11The Brauns reported $46,468 in individual retirement
accounts as of Jan. 6, 2003. The Brauns reported $44,609 as of
July 22, 1999.
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Last modified: May 25, 2011