Simone Joye - Page 22




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          petitioner responded by letter on July 8, 1998.                             
               On the record before us, we find that petitioner has failed            
          to show that respondent abused respondent’s discretion in deter-            
          mining in the notice of determination to proceed to collect the             
          additions to tax under section 6651(a)(1) and (2) that respondent           
          assessed with respect to each of petitioner’s taxable years 1987,           
          1988, and 1989.9                                                            
               Interest                                                               
               We construe petitioner’s position with respect to the                  
          interest at issue as a request to review respondent’s failure to            
          abate interest under section 6404(e).  See supra note 4.  We have           
          jurisdiction to review respondent’s determination in the notice             
          of determination not to abate interest.  Sec. 6404(i); Katz v.              
          Commissioner, 115 T.C. 329, 340-341 (2000).                                 
               Petitioner contends that respondent abused respondent’s                
          discretion in failing to abate interest on petitioner’s unpaid              
          liability for each of the years 1987, 1988, and 1989 because:               
               respondent * * * has performed a ministerial act re-                   


               9With respect to petitioner’s contention that she would be             
          penalized if the Court were to allow respondent to proceed to               
          collect the additions to tax at issue under sec. 6651(a)(1) and             
          (2), we note that additions to tax such as those under sec.                 
          6651(a)(1) and (2) are remedial, and not punitive.  See Helvering           
          v. Mitchell, 303 U.S. 391, 401 (1938); Ianniello v. Commissioner,           
          98 T.C. 165, 187 (1992).  Such additions to tax are provided                
          primarily as a safeguard for the protection of the revenue and to           
          reimburse the Government for the significant expense of investi-            
          gation and the loss resulting from a taxpayer’s actions or                  
          omissions.  See Helvering v. Mitchell, supra.                               





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