Doreen Boyd - Page 11

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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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