- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011