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case were attributable to petitioners. There was no erroneous or
dilatory performance of a ministerial act by an officer or
employee of respondent during this period and any delays
perceived by petitioners during this period were of petitioners’
own making. Therefore, on this record, the Commissioner’s
refusal to abate interest was not an abuse of discretion under
section 6404(e). Respondent’s determination is sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011