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their 1990 tax year.
On August 14, 1997, respondent issued a final determination
denying petitioners’ interest abatement claim.3 Petitioners'
amended petition, with respondent’s final determination attached,
was filed on October 27, 1997.
As of May 13, 1998, petitioners owed $6,680.94 in tax and
interest. Petitioners also owed about $1,910 under section
6651(a) for the addition to tax for failing to timely file their
return and pay tax. The amount of interest due on the addition
to tax under section 6651(a) was $1,456.94 on May 13, 1998.
OPINION
A. Abatement of Interest
1. Contentions of the Parties
Petitioners contend that respondent’s failure to abate
interest on their 1990 tax liability from April 15, 1991, to the
present was an abuse of discretion. Petitioners contend that too
much time passed from when respondent began the audit around June
1992 to when respondent issued the notice of deficiency on March
24, 1994. Petitioners contend that Morrow should have settled
the case as quickly as Keenan did after she received the case.
Respondent contends that there were no errors or delays due
to ministerial acts by respondent and that respondent's refusal
3 On brief, petitioners and respondent argue that period in
dispute is from Apr. 15, 1991, to present. We treat the issue
before us as stated in the briefs.
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