- 9 - We have considered all of petitioner’s complaints regarding respondent’s conduct in connection with the deficiency cases, including the claim made in petitioner’s brief that the 1981 deficiency was erroneously overstated in the stipulated decision entered in the case involving that year, and find that none supports a ground for relief under section 6404(e). Respondent’s conduct in connection with the deficiency cases provides no basis to conclude that respondent’s failure to abate interest was an abuse of discretion. Petitioner paid the deficiencies on various dates between September 19 and November 28, 1994. None of the interest has been paid. As of the date that each of the deficiencies was paid, interest ceased to run on the underlying tax. However, because no interest was paid, and because interest that accrued after December 31, 1982, is compounded daily, interest continued to accrue (and continues to accrue) after the dates that the deficiencies were paid. Interest accruing after the dates that the deficiencies were paid is due to petitioner’s failure to pay the outstanding interest obligations and not due to a ministerial act on respondent’s part. See Douponce v. Commissioner, T.C. Memo. 1999-398. Respondent’s failure to abate interest for any period after the dates that the deficiencies were paid was not an abuse of discretion.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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