The case was one count of failure to provide information in connection with a federal tax returm 26USC 7203.
The Penalty code fraud - IRC 663 was used by the civil IRS agent
I was trying to get it changed to accuracy 20% but that is just one of the items currently being reviewed.
As originally stated I want to abate the continuing interest for an unreasonable amount of time. The penalty I am working on but the form it to filed after the penalty is determined. I wanted help with abating the interest. 1997 to 2008 when the tax was paid the day it was determined in court dec 2006 seems unfair.
The IRS is authorized to abate interest only in limited circumstances, including:
Interest attributable to deficiency or delay in payment caused in whole or in part by an unresonable error or delay of IRS personnel in performing ministerial or managerial act [IRC 6404(e)(1)]
Interest during the extended period for filing and paying tax in a presidentially declared disaster area [IRC 6404(i)
Interest on erroneous refunds until the date the IRS demands repayment (provided the error was not caused by the taxpayer and the refund is $50,000 or less) [IRC 6404(e)(2)[