- 5 - Form 843, Claim for Refund and Request for Abatement, requesting abatement of the interest, and addition to tax on the grounds that they were caused by IRS errors and delays. V. Amended Return On October 8, 2002, petitioner submitted to respondent a Form 1040X, Amended U.S. Individual Income Tax Return, for taxable year 1998, amending the 1998 Federal income tax return to reflect the additional income of $75,000, and an increase in itemized deductions of $25,032 for legal fees and costs. Petitioner’s $14,487 payment of her tax liability was credited on January 15, 2003. In September 2003, respondent processed the amended return, allowed the itemized deductions, and adjusted the return, decreasing petitioner’s assessed tax. Nevertheless, there was still a balance due on petitioner’s account for 1998. VI. Notice of Determination On December 30, 2003, respondent issued a notice of determination. The Appeals officer determined that petitioner was not entitled to an interest abatement because the delays in resolving her delinquent income tax liability were directly attributable to claims that she was not liable for the tax on the amounts she received in her lawsuit. Petitioner timely filed a petition on January 23, 2004. Petitioner asserts that the interest and addition to tax should be abated due to inconsistent positions and administrativePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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