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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.
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Last modified: March 27, 2008