- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011