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petitioners' numerous bank accounts, to suspend petitioners'
audit until a related audit of NERC was completed, and to refer
the instant case to the CID are all acts requiring the exercise
of judgment and discretion and, therefore, are not ministerial
acts. Because there is no ministerial act by respondent's
employees or officers that caused delay, respondent could not,
pursuant to section 6404(e), abate interest. Accordingly, we
uphold respondent's final determination not to abate interest.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011