- 2 - respondent’s refusal to abate interest constitutes an abuse of discretion. Background The parties’ stipulations are incorporated into this Memorandum Opinion by reference and, accordingly, are found as facts in the instant case. At the time he filed his petition, petitioner resided in Tampa, Florida. On August 22, 2001, Internal Revenue Service (IRS) Agent Julie A. Kelley (Agent Kelley) initiated examination of petitioner’s 1999 return. On September 10, 2001, Agent Kelley initiated examination of petitioner’s 1998 return. On September 25, 2001, Agent Kelley worked on notices of proposed adjustments to items reported on petitioner’s income tax returns for 1998 and 1999. On September 27, 2001, Agent Kelley sent petitioner a letter requesting an extension of the limitations period for assessing petitioner’s taxes for 1998. Agent Kelley drew up a Revenue Agent Report on October 2, 2001. Petitioner discussed the Revenue Agent Report with Agent Kelley on October 5, 2001. Subsequently, petitioner discussed the Revenue Agent Report with his representative, Laymond Cloud (Mr. Cloud), and informed Agent Kelley on October 22, 2001, that he would not agree to sign a report until adjustments to all of his returns under audit were consolidated into one report. On October 24, 2001, Agent KelleyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: March 27, 2008