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August 31, 2001, the parties submitted a decision document, which
we filed as a Stipulation of Settlement Between the TMP and
Respondent (the Greenwich settlement). On January 17, 2002, we
entered an order and decision resolving the Greenwich litigation.
On January 27, 2003, respondent assessed against petitioners
income tax deficiencies and interest attributable to the
Greenwich settlement. On October 27, 2003, petitioners paid all
of the tax, but not the interest, attributable to the Greenwich
settlement. On February 6, 2004, petitioners mailed to
respondent Forms 843, Claim for Refund and Request for Abatement
(interest abatement claims), with respect to the accrued interest
attributable to the Greenwich settlement.
On February 10, 2004, respondent issued to petitioners a
Final Notice--Notice of Intent to Levy and Notice of Your Right
to a Hearing for 1982 through 1984, and petitioners timely
requested a section 6330 hearing. On April 2, 2004, respondent
issued to petitioners a Notice of Federal Tax Lien Filing and
Your Right to a Hearing Under IRC 6320, for 1983 and 1984, and
petitioners timely requested a section 6320 hearing. On April 7,
2004, respondent denied petitioners’ interest abatement claims.
On May 5, 2004, petitioners submitted a request to respondent’s
Appeals Office to review the denial of their interest abatement
claims.
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Last modified: May 25, 2011