Robert Banat - Page 1

                                 T.C. Memo. 2000-141                                  

                               UNITED STATES TAX COURT                                

                             ROBERT BANAT, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2237-97.                    Filed April 14, 2000.           

                    P filed a petition for a determination that R’s                   
               failure to abate interest under sec. 6404(e), I.R.C.,                  
               with respect to petitioner’s 1985, 1986, and 1987                      
               taxable years was an abuse of discretion and for an                    
               abatement order.                                                       
                    Held:  P has not established any erroneous or                     
               dilatory ministerial acts by R giving rise to the                      
               assessment of interest after P was first contacted in                  
               writing about the deficiency and before interest was                   

               Hedy P. Forspan, for petitioner.                                       
               Thomas J. Kerrigan, for respondent.                                    

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