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OPINION OF THE SPECIAL TRIAL JUDGE
CARLUZZO, Special Trial Judge: On March 25, 1997,
respondent issued a notice of final determination denying
petitioner’s request to abate interest on deficiencies for the
years 1980 and 1981. On June 16, 1997, respondent issued a
notice of final determination denying petitioner’s request to
abate interest on deficiencies for the years 1982 and 1983. In
response to each notice a timely petition was filed pursuant to
section 6404(g)2. The two abatement cases were consolidated for
trial, briefing, and opinion.
The issue for decision is whether respondent’s failure to
abate accrued interest assessed on deficiencies for the years
1980 through 1983, inclusive, as requested in petitioner’s claims
for abatement was an abuse of discretion.
Background
Some of the facts have been stipulated and are so found. At
the time the petitions in these cases were filed, petitioner
resided in New Canaan, Connecticut.
Although not readily apparent from the magnitude of the
record in these cases, which includes 109 exhibits and the
2After the petitions were filed in these cases, 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. 685, 743, 745.
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Last modified: May 25, 2011