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Petitioners have not shown that respondent caused any
unreasonable error or delay in the evaluation of their offer-in-
compromise forms submitted on November 27, 2002. Moreover, any
delays in processing the offer-in-compromise were attributable in
significant part to petitioners’ failure to provide the revenue
officer with requested information or clarification of other
information.
Petitioners’ assertion that respondent failed to meet with
them to resolve this case despite several attempts by petitioners
to do so is without support. Petitioners provided no specific
information regarding who they tried to contact or when.
Additionally, Ms. Russo’s casenotes indicate that she promptly
responded to all telephone calls and correspondence.
Petitioners have failed to establish that respondent caused
any unreasonable errors or delays in the performance of a
ministerial or managerial act. Therefore, petitioners have
failed to show that respondent abused his discretion by rejecting
their request for an abatement of interest. We hold that
respondent did not abuse his discretion by rejection petitioners’
request for an abatement of interest.
C. Appropriateness of the Federal Tax Lien
During their section 6330 hearing, petitioners requested
that respondent release the Federal tax lien. However,
petitioners did not allege in their petition that respondent
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Last modified: November 10, 2007