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Abatement of Interest and Adjustment of Penalties
Petitioners challenge respondent’s collection action on the
grounds that respondent did not properly account for an agreement
reached between petitioners and respondent’s Milwaukee Problem
Resolution Office to abate all interest and adjust the section
6662(e) penalty to zero for each of the taxable years at issue.
Ms. Roberts testified that the agreement reached between the
parties applied to the original assessment only and did not apply
to the period after the assessment where petitioners’ outstanding
liability went unpaid.
Our review of the record12 indicates that respondent did, in
fact, abate interest and adjust the section 6662(e) penalty to
zero with respect to the original assessment for each of the
taxable years in issue. We believe Ms. Roberts’s testimony that
the agreement between the parties applied to the original
assessment only and not to the period after the assessment
through the present. Accordingly, we hold that respondent did
properly abate and adjust the interest and the section 6662
penalties with respect to the assessments made for petitioners’
1993 and 1994 taxable years.
12 Specifically, respondent’s account statements for
petitioners’ 1993 and 1994 taxable years. These documents were
provided to petitioners, and petitioners offered no evidence to
contradict their content.
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Last modified: March 27, 2008