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deficiency”. Sec. 6404(e)(1). Stated differently, section
6404(e)(1) does not provide for the abatement of interest
assessed on a deficiency for the period between the dates that
the return is due and the taxpayer is contacted in writing with
respect to the deficiency. In his brief, petitioner appears to
have recognized this limitation, but he does not expressly
concede entitlement to abatements of interest that accrued prior
to the relevant dates, which are not in dispute. In any event,
for each of the deficiency years, respondent’s failure to abate
interest for the period that ran from the due date of the return
until respondent contacted petitioner in writing with respect to
the deficiency is consistent with the statute. Because the
statute does not authorize an abatement of interest for such
period, respondent’s failure to do so is not an abuse of
discretion.
Petitioner’s primary contention is that interest on the
deficiencies should be abated because of respondent’s conduct in
connection with the deficiency cases. According to petitioner,
the deficiency cases could have been concluded much sooner than
they were if not for certain actions on respondent’s part.
First, we disagree with petitioner’s suggestion that progress in
the deficiency cases was controlled by respondent. More
importantly, to the extent that petitioner identified specific
actions taken by respondent in the deficiency cases, such actions
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Last modified: May 25, 2011