John B. Cosgriff - Page 8

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          was not arbitrary, capricious, or without sound basis in fact or            
          law.  See Woodral v. Commissioner, supra at 23.                             
               Respondent reconsidered petitioner’s 1992 tax liability                
          despite his failure to file a petition contesting the notice of             
          deficiency.  Thereafter, respondent exercised discretion in                 
          abating a substantial portion of the prior assessment.  Any                 
          errors or delays were attributable to petitioner’s cancellation             
          of scheduled appointments and his failure to timely produce                 
          requested information.  Accordingly, we hold that respondent’s              
          denial of petitioner’s claim to abate interest was not an abuse             
          of discretion.                                                              

                                               Decision will be entered for           

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