Kenneth D. Hanks - Page 2




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          Procedure.  The Court agrees with and adopts the opinion of the             
          Special Trial Judge which is set forth below.                               
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               DEAN, Special Trial Judge:  On July 31, 2000, respondent               
          issued a notice of final determination denying petitioner's claim           
          for the abatement of interest for tax years 1990 and 1991.                  
          Petitioner challenged the determination by timely filing a                  
          petition under section 6404(i), as in effect at the time the                
          petition was filed, and Rule 281.                                           
               The issue for decision is whether respondent abused his                
          discretion by failing to abate assessments of interest relating             
          to petitioner's 1990 and 1991 tax years.                                    
                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioner resided in                    
          Hutchins, Texas, at the time his petition was filed with the                
          Court.                                                                      
               Petitioner's 1990 and 1991 Federal income tax returns were             
          subjected to examination by the Internal Revenue Service (IRS)              
          beginning on February 2, 1993.  His first meeting with the                  
          revenue agent assigned to perform the examination took place on             
          March 1, 1993.  The revenue agent referred petitioner's case to             
          the Criminal Investigation Division (CID) of IRS on November 2,             








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