Dennis and Nancy Flynn - Page 9

                                        - 9 -                                         
          payment addition for 1995 and 1996.  On October 11, 2001, Leiba             
          wrote Estoll to accept respondent’s settlement offer.  On October           
          29, 2001, respondent’s Appeals Office confirmed that respondent             
          had agreed to abate the late payment addition for 1993.                     
               On December 10, 2001, Leiba wrote to Charles Checchi                   
          (Checchi), respondent’s area director in San Francisco, to ask              
          him to approve petitioners’ claim for refund of the late payment            
          addition for 1995 and 1996.                                                 
          C.   Administrative Costs Claim                                             
               On January 22, 2002, Leiba wrote to Checchi to request                 
          payment of petitioners’ administrative costs.  On March 28, 2002,           
          Checchi wrote Leiba to inform him that he had spoken to Estoll              
          about the case and decided not to reconsider the settlement for             
          1995 and 1996.                                                              
               On April 23, 2002, Checchi wrote to inform Leiba that he was           
          reassigning petitioners’ claim for administrative costs to an               
          Appeals Office separate from the one that had considered                    
          petitioners’ previous claims.                                               
               On February 10, 2003, Darwyn Pearl (Pearl), Appeals Team               
          Manager in Seattle, Washington, wrote to petitioners.  Pearl                
          stated that petitioners’ claim for administrative costs under               
          section 7430 was disallowed because (1) petitioners had not                 
          substantially prevailed on the amount in controversy or on the              








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011