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MEMORANDUM OPINION
HALPERN, Judge: This case is before the Court for review of
respondent’s failure to abate interest.1 By notice dated
November 8, 1996, respondent made his final determination not to
abate interest with respect to petitioner’s 1985, 1986, and 1987
taxable (calendar) years.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time the petition was
filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
At the time the petition was filed, petitioner resided in
Brooklyn, New York.
This case was submitted for decision without trial. See
Rule 122. The parties have agreed to a stipulation of facts (the
stipulation). The stipulation, with attached exhibits, is
incorporated herein by this reference. Certain other exhibits
were received into evidence. We shall not here repeat the
stipulation or recite the contents of the other exhibits. We
shall, however, summarize certain facts as an aid to
understanding our discussion.
1 A prior report in this case appears at Banat v.
Commissioner, 109 T.C. 92 (1997).
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