I have to write a tax memo about the following case: Your clients, Sam and Sandra Smith, are upset because the IRS has refused to abate interest charges assessed for a disallowed charitable contribution on their 2008 tax return. Both the taxpayers and the IRS agree on the disallowance of the deduction, because the recipient of the donation was not a qualified charitable organization. The IRS initially issued a notice in 2011 informing the taxpayers that their deduction was disallowed. The notice, however, was returned to the IRS because it was sent to the address that was used on the 2008 tax return, rather than their current address. The IRS apparently learned of the taxpayers’ new address in 2014 when they sent the assessment to the taxpayer’s new address. Shortly after receiving the notice the taxpayers signed an agreement stating that they agreed the deduction claimed was invalid. The next correspondence the taxpayers received from the IRS was in 2019, containing the assessment for additional taxes plus interest from 2014 (and from April 15, 2009 until 2011). The taxpayers said a representative from the IRS apologized for sending the notice so late. They said it had been misplaced by the agency since 2013. Your clients do not believe they should be charged any interest.