- 3 - The letter contained the heading "Interest & Penalty Abatement Request". The letter was accompanied by a $22,000 check and requested that respondent "apply the amount to tax principal only" and accept the amount as "payment in full" of petitioners' outstanding "tax principal" for taxable years 1994 and 1995. The letter further requested that all interest and penalties for 1994 and 1995 be abated due to "financial hardships". The letter alleged that petitioners had been unaware, when they signed the consent to the assessment of their tax liabilities arising from the examination of their 1994 and 1995 taxable years, that the amounts consented to included penalties and would continue to accrue interest until paid. The letter concluded: "We are requesting abatement of the penalty and interest and the Service accept the $22,000.00 as payment. Please advise us of your decision." Subsequent to sending the foregoing letter, petitioners received a notice from respondent's Automated Collection System dated December 23, 2004, that listed assessed balances, accrued interest, and late payment penalties still owed with respect to petitioners' 1994 and 1995 taxable years. 3(...continued) dates entered next to petitioners' signatures were both June 14, 2002.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: March 27, 2008