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was considered and the allowable amount was determined.
This delay was not caused by a Service employee’s
failure to perform a ministerial act.
On November 26, 1999, petitioner filed a petition with this
Court for review of respondent’s failure to abate interest under
section 6404. See Rule 281(a). The petition disputes the sum of
$24,989.86 and alleges, in part, that “The interest calculation
is due in part to tax [deficiencies] assessed in error.”12
G. Recomputation of Petitioner’s Liability for Interest
Sometime after respondent had formally disallowed
petitioner’s claim for abatement and petitioner had filed his
petition with this Court, respondent realized that petitioner’s
account for 1986 had been credited with only a portion of
petitioner’s overpayment for 1985; i.e., only
$12,058.42 (i.e., $6,166.80 + $5,891.62) of the $17,866.18
overpayment for 1985 had been credited against petitioner’s
liability for 1986. See supra E. Respondent corrected this
error. As a result, petitioner’s liability for interest for 1986
was reduced significantly. As of May 31, 2000, petitioner’s
liability for interest for 1986 was $12,155.57, or approximately
one-half of the amount shown on the notice issued by respondent
on August 24, 1998. See supra F.
12 See supra note 2 regarding our lack of jurisdiction to
consider any claim for abatement of tax, penalty, or addition to
tax.
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