- 4 - the redetermined deficiencies (the deficiencies) were entered in 1994. Petitioner paid the 1980 and 1982 deficiencies on September 19, 1994; he paid the 1983 deficiency on September 20, 1994; and he paid the 1981 deficiency on November 28, 1994. None of the interest that has accrued on any of the deficiencies has been paid. In claims for abatement originally made in December 1994 and resubmitted in February 1997, petitioner requested abatements of all of the interest that had accrued on the deficiencies. As noted above, petitioner’s claims were denied in notices of final determination issued by respondent in 1997. Discussion Subject to exceptions not relevant here, interest on a deficiency begins to accrue on the due date of the return and continues to accrue, compounding daily, until payment is made. See secs. 6601(a), 6622. The Commissioner has the authority to abate the assessment of interest on a deficiency if the accrual of such interest is attributable to an error or delay by an official or employee of the Internal Revenue Service in performing a ministerial act. See sec. 6404(e)(1).3 A ministerial act means a procedural or 3Sec. 6404(e) was amended by sec. 301 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, 110 Stat. 1452, 1457 (1996), to permit respondent to abate interest with respect to an “unreasonable” error or delay resulting from “managerial” or (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011