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over the abatement of interest under section 6404(e) as that
provision, by its very terms, does not operate until after there
has been an assessment of interest. There has been no assessment
of interest in this case as respondent has been precluded under
section 6213(a) from making any assessment until the decision of
this Court becomes final.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011