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Appeals Office received the file. On August 5, 2003, the
assessment date was entered into the IRS’s computer system.
On August 25, 2003, the IRS assessed deficiencies in
petitioner’s income tax, with interest, as follows: For 1998,
a deficiency of $2,308 and $833.54 of accrued interest (interest
calculated from April 16, 1999, to August 25, 2003); for 1999,
a deficiency of $26,916 and $6,885.15 of accrued interest
(interest calculated from April 16, 2000, to August 25, 2003);
for 2000, a deficiency of $34,328 and $4,948.79 of accrued
interest (interest calculated from April 16, 2001, to August 25,
2003).
On September 22, 2003, petitioner filed Form 843, Claim for
Refund and Request for Abatement. Petitioner requested interest
abatement as follows: For 1998, $312.55 of interest abatement;
for 1999, $3,430.19 of interest abatement; and for 2000,
$3,648.65 of interest abatement. Subsequently, the IRS sent
petitioner a letter stating that petitioner’s request for
interest abatement had been forwarded to respondent’s Memphis
Office for review.
After assignment of the request for interest abatement to
Revenue Agent Susan Harbin (Agent Harbin) in Jacksonville,
Florida, on September 29, 2004, Agent Harbin suspended the
interest which had accrued during a portion of the examination
and otherwise proposed to deny petitioner’s request for interest
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Last modified: March 27, 2008