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Mr. Caple also raised the issue of whether respondent had
abated interest and adjusted accuracy-related penalties with
respect to their accounts for 1993 and 1994. Respondent had
previously agreed to abate interest and adjust the penalties
assessed against petitioners, pursuant to an agreement reached
between petitioners and respondent’s Milwaukee Problem Resolution
Office. During the hearing, petitioners questioned whether
respondent had, in fact, properly abated the interest and
adjusted these penalties per their agreement. Ms. Roberts
reviewed petitioners’ account records during the hearing and
explained to them that these transcripts showed that the section
6662 penalties had been adjusted to zero and the interest had
been abated. Per petitioners’ request, Ms. Roberts then sent a
copy of these account statements/transcripts to petitioners
following the hearing.
On June 29, 2004, petitioners submitted to respondent a Form
656, Offer in Compromise (OIC). Petitioners offered to settle
the outstanding amount of tax owed by them as follows: (1) A
payment of $100 (to be obtained from “checking accounts,
investment accounts, and selling autos”10), (2) the application
9(...continued)
Ashley was a college student and covered under their health
insurance plan.
10 Petitioners admitted, both during the hearing and when
this matter was heard by the Court, that in 1999, they purchased
(continued...)
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