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Petitioner also claims that respondent’s officers failed to
inform her that there would be due from her additional amounts
for FICA taxes, FICA penalties, or interest when she reached a
settlement with respondent as to the deficiencies for 1988 and
1990. However, petitioner’s claim in this regard is without
merit as the parties’ stipulation states the contrary.
Because petitioner failed to produce evidence that the
interest was excessive in amount, assessed after the expiration
of the period of limitations properly applicable thereto, or
erroneously or illegally assessed and because her delay in paying
the tax and interest was not attributable to any ministerial act
that an officer of the IRS performed in an erroneous or dilatory
manner, there was no abuse of discretion in respondent's denial
of petitioner's request for abatement of interest.
Petitioner has raised other arguments that we have
considered in reaching our decision. To the extent that we have
not discussed these arguments, we find them to be without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011