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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
respondent.
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