Edward Lee Renfrow - Page 3

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               At trial, petitioner agreed to pay the deficiency in tax.               
          However, petitioner refuses to pay the statutory interest accrued            
          on the deficiency.  Petitioner suggests that he is not                       
          responsible for the interest due to respondent's delay in                    
          notifying him of the deficiency.  Petitioner does not cite any               
          authority for his position.                                                  
               Section 6601 provides for the accrual of interest on any                
          underpayment of tax from the date the tax becomes due, until the             
          date the tax is paid.  Section 6404(e)(1) provides:                          
               (e) Assessments of Interest Attributable to Errors                      
               and Delays by Internal Revenue Service.--                               
                         (1)  In general.-- In the case of any                         
                    assessment of interest on--                                        
                              (A) any deficiency attributable in                       
                         whole or in part to any error or delay                        
                         by an officer or employee of the                              
                         Internal Revenue Service (acting in his                       
                         official capacity) in performing a                            
                         ministerial act, or                                           
                              (B) any payment of any tax                               
                         described in section 6212(a) to the                           
                         extent that any error or delay in such                        
                         payment is attributable to such officer                       
                         or employee being erroneous or dilatory                       
                         in performing a ministerial act,                              
                    the Secretary may abate the assessment of all or                   
                    any part of such interest for any period.  For                     
                    purposes of the preceding sentence, an error or                    
                    delay shall be taken into account only if no                       
                    significant aspect of such error or delay can be                   
                    attributed to the taxpayer involved, and after the                 
                    Internal Revenue Service has contacted the                         
                    taxpayer in writing with respect to such                           
                    deficiency or payment.  [Emphasis added.]                          

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