- 8 - the poor economy, his lack of knowledge of the tax law, and his fear of losing his job. Petitioner requested guidance on obtaining an abatement of interest and relief from the additions to tax. By letter dated August 9, 2005, the settlement officer detailed the requirements for a request for relief from additions to tax,7 informed petitioner that respondent was required by statute to assess interest in his case and that the interest could not be abated, and referred petitioner to the Internal Revenue Manual for further information. By letter dated August 29, 2005, petitioner once again requested the abatement of interest and relief from the additions to tax because of the downturn in the economy and his lack of knowledge regarding the tax implications of employee stock options. On November 18, 2005, respondent issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). The notice of determination stated that respondent had verified that all statutory and administrative requirements had been met, that respondent had addressed all of petitioner’s arguments raised at the face-to-face hearing, and that respondent had determined that the lien appropriately balanced the Government’s need for the efficient collection of taxes and petitioner’s concern that the 7The settlement officer used the term “penalties” in the letter, but she was referring to additions to tax.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008