- 12 -
Respondent’s failure to abate interest for the period
November 14 through December 13, 2001, was not an abuse of
discretion.
Respondent’s failure to abate interest for the period
December 14, 2001, through February 25, 2002, was not an abuse of
discretion, other than to the extent to which such failure
related to one or more managerial acts.
Respondent’s failure to abate interest for the period
February 26 through May 30, 2002, was not an abuse of discretion.
Krogue’s error in requiring monthly payments of $600,
instead of the $400 that had been agreed upon, was an error in
performing a ministerial act.
Respondent’s failure to abate interest for the period June
26 through December 13, 2002, was not an abuse of discretion.
Discussion
1. Parties’ Contentions, Summary, and Conclusions
Petitioner brought the instant case to seek abatement of
interest. (See supra note 3, as to penalties and additions to
tax.) Respondent moved for summary judgment.
Petitioner contends that respondent’s personnel “provided
inaccurate information * * * [and] were dilatory in performing
their managerial and ministerial acts”, and so this Court should
order an abatement of interest. Respondent contends that: (1)
The delay in petitioner’s tax payment (giving rise to the
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: March 27, 2008