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that their financial circumstances would cause them to sustain
significant economic hardship if the interest were not abated.
Respondent summarily denied petitioners’ abatement request
on March 17, 2003. In their administrative appeal, submitted on
April 7, 2003, and supplemented by written correspondence on
January 11, 2004, petitioners asserted their entitlement to a
partial abatement in an unspecified amount, reiterating equitable
considerations along the same vein as the aforementioned fairness
arguments. Respondent rejected petitioners’ appeal in a final
determination on January 18, 2005, citing the protracted
partnership litigation as the predominant factor contributing to
the delay.
On January 18, 2005, respondent sent petitioners a letter
entitled Full Disallowance - Final Determination, which reads in
part as follows:
Dear Mr. & Mrs. Momot:
This letter is to inform you that we are disallowing
your request for an abatement of interest. We call
this decision a determination. This letter is our
final determination for purposes of Internal Revenue
Code Section 6404.
We regret that our final determination is to deny your
request for an abatement of interest. We had to deny
your request for the following reason(s):
• After review of available records and other
information, we did not find any unreasonable
errors or delays on our part that merit the
abatement of interest for tax years 1985 and 1986.
(See Form 843, Claim). The time it took for the
Tax Court Decision against Crystal Star Eagle with
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Last modified: May 25, 2011