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or payment and if no “significant aspect” of the error or delay
is attributed to the taxpayer. Sec. 6404(e)(1); Nerad v.
Commissioner, T.C. Memo. 1999-376. Because Congress did not
intend for section 6404(e) to be used routinely, we will order
abatement only “where failure to abate interest would be widely
perceived as grossly unfair.” Lee v. Commissioner, 113 T.C. 145,
149 (1999); H. Rept. 99-426, at 844 (1985), 1986-3 C.B. (Vol. 2)
1, 844; S. Rept. 99-313, at 208 (1986), 1986-3 C.B. (Vol. 3) 1,
208.
Petitioner argues that interest should be abated because:
(1) Hardships beyond his control prevented him from complying
with Federal income tax laws; (2) respondent failed to include
vital evidence in the stipulation of facts; (3) just before
trial, respondent’s attorney attempted to coerce petitioner into
dropping his abatement claim; and (4) respondent delayed
proceedings when petitioner was willing to settle his income tax
liabilities. Petitioner’s hardships, the content of the
stipulation of facts, and the coercion allegation are not proper
grounds for us to order interest abatement. Additionally, we
find these allegations to be unsupported by the evidence.
In order for petitioner to prevail, there must be an error
or delay in performing a ministerial act that is attributable to
respondent. A “ministerial act” does not involve the exercise of
judgment or discretion. Sec. 301.6404-2T(b)(1), Temporary
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