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consideration of his offer in compromise. Respondent denied
petitioner’s interest abatement claim.12
The entire course of events, from petitioner’s first request
to compromise their tax liability through respondent’s final
denial of his claim, took more than 3 years.
Notice of Intent To Levy and Payment
Respondent sent the Brauns a notice of intent to levy on
March 24, 2003, and a Form 668-W, Notice of Levy on Wages,
Salary, and Other Income, on July 2, 2003. The Brauns paid
respondent $8,409.92 on July 15, 2003, approximately 5 months
after petitioner received respondent’s final determination
rejecting his offers in compromise. The Brauns’ payment
satisfied their tax liabilities for 1994 and 1997, but left
outstanding accrued and unassessed interest.13 Petitioner
appealed to our Court respondent’s determination not to abate
interest for 1994 and 1997.
12On Feb. 10, 2003, the Appeals Office also notified the
Brauns that their interest abatement claim would be denied.
Petitioner received a letter from respondent denying his interest
abatement claim 2 days later.
13Of the Brauns’ $8,409.92 payment, respondent applied
$8,087.71 to the Brauns’ 1994 account and $322.21 to the Brauns’
1997 account.
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Last modified: May 25, 2011