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to section 6404(g) and Rule 280.2 The sole issue for decision is
whether respondent’s denial of petitioners’ request to abate
interest was an abuse of discretion.
Background
The parties have stipulated some of the facts, which are
incorporated in our findings by this reference. When they
petitioned this Court, petitioners resided in Lucedale,
Mississippi.
Petitioners timely filed joint Federal income tax returns
for taxable years 1989 and 1990. On June 6, 1991, respondent’s
examining agent mailed petitioners a letter informing them that
their 1989 return had been selected for examination. During the
examination, the examining agent solicited petitioners’ consent
to extend the period of limitations to assess tax with respect to
taxable year 1989, and they agreed.
On November 18, 1992, respondent mailed petitioners a 30-day
letter, proposing deficiencies of $14,088 and $14,417, and
accuracy-related penalties of $2,818 and $2,883, for taxable
years 1989 and 1990, respectively. On December 10, 1992,
petitioners responded by filing a protest, requesting
consideration of their case by respondent’s Appeals Office. By
2 Sec. 6404(g) was redesignated sec. 6404(i) by the Internal
Revenue Service Restructuring & Reform Act of 1998, Pub. L. 105-
206, secs. 3305(a), 3309(a), 112 Stat. 743, 745, with respect to
taxable years beginning after Dec. 31, 1997.
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