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interest should be abated for 1981. Petitioners assert that they
requested that respondent abate interest during settlement
conferences with respondent and that the Court should treat the
notice of deficiency as respondent's "final determination" not to
abate interest.
This matter was called for hearing at the Court's motions
session in Washington, D.C. Counsel for respondent appeared at
the hearing and presented argument in support of the pending
motion. Further, respondent stated that, at the time of the
hearing, petitioners were not precluded from filing a request for
abatement of interest. Although petitioners did not appear at
the hearing, they did file a written statement with the Court
pursuant to Rule 50(c). Petitioners' Rule 50(c) statement
includes allegations that the Court should treat the notice of
deficiency in this case as respondent's final determination to
deny petitioners' request to abate interest in light of
respondent's final determination denying a request for abatement
of interest filed by T. John Tsalaky, petitioner James Bourekis'
brother-in-law and partner in PCS. (T. John and Magdaline B.
Tsalaky filed a petition for review of respondent's denial of
their request to abate interest. That matter is currently
pending before the Court at docket No. 7012-97.) Petitioners
contend that, under the circumstances, it would be "futile,
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Last modified: May 25, 2011