Michael W. Braun - Page 8

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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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