- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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