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employed for processing the 1985 refund claim and the accrual of
interest that is the subject of petitioners’ interest abatement
claim for the 1981 tax year.9
We note that a significant aspect of the delay in the
ultimate payment of the 1981 tax liability is attributable to
petitioners. They chose to await the determination of the refund
claim for 1985, while all along requesting holds on collection.
We have considered all of the arguments raised by the
parties and to the extent not discussed herein find them to be
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
9 This is not the case, for example, in which a claim for
refund was allowed, and, after a specific request by the taxpayer
to apply the refund to the tax year in issue, the Commissioner
failed to act on the taxpayer’s request. See Mankita v.
Commissioner, T.C. Memo. 1999-420 (in which we rejected a
taxpayer’s claim, under the facts of that case, that an abatement
of interest should have been allowed because the Commissioner had
failed to apply a refund to the tax year in issue).
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