- 6 -
Cir. 1995). Subsequently, the Supreme Court denied petitioner's
petition for a writ of certiorari. See Taylor v. United States,
551 U.S. 1222 (1996).
On March 1, 1994, after petitioner's conviction and prior to
the so-called section 2255 proceedings, the District Counsel
notified the Examination Division that the criminal aspects had
been concluded, and the Examination Division was authorized to
proceed with the civil liability. The revenue agent's report was
sent to petitioner on April 15, 1994. Thereafter there were
several meetings with petitioner and the Examination Division.
In November 1994, the case was sent to the Appeals Office. A
notice of deficiency was issued to petitioner and Ms. Taylor on
February 16, 1996, for the taxable years 1984 through 1988 after
the parties were unable to settle the matter satisfactorily.
Petitioner filed a petition with this Court at docket No. 8493-
96, and, on April 18, 1997, a stipulated decision was entered in
that case. The petition filed herein seeks a redetermination of
the disallowance of the request for abatement of interest for the
1986 and 1987 taxable years.
Discussion
Section 6404(e) provides in relevant part:
(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
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