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providing petitioners with an escrow demand letter for their
lender.
Mr. Minor abated for reasonable cause $596.02 of the
addition to tax for failure to timely pay tax accruing from July
31 to November 30, 2003 as follows:
1995, 1996, 1998: No penalty applicable for this
period because the 50-month period for assessment of
this penalty has already expired
1999: $48.62 ($2,431 tax due per return multiplied by
2 percent (i.e., .5 percent for 4 months))
2000: $510.88 ($26,144 tax due per return less $600
general tax credit multiplied by 2 percent)
2001: $36.52 ($1,826 tax due per return multiplied by
2 percent)
On October 31, 2003, petitioners paid in full their
outstanding income tax liabilities for the years in issue of
$64,928.88.
D. Notice of Determination
On December 11, 2003, respondent sent to each petitioner a
Notice Of Determination Concerning Collection Action Under
Section 6320 (notice of determination). In the notice of
determination, respondent denied all of petitioners’ requests.
With respect to petitioners’ request to abate interest,
respondent denied their request because
the Jacksons have not fully paid their liabilities.
They state that the delay of their refinance caused
them to accrue additional interest, but, the refinance
was not secured. Had it been secured, there was
insufficient funds available in the refinance to fully
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Last modified: May 25, 2011