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notice erroneously overstating the amount of interest due for
1986. In this regard, petitioner testified that “had they had
the right figures, I could have settled it back then”. However,
we are unable to accept this assertion at face value. See
Tokarski v. Commissioner, 87 T.C. 74 (1986). Petitioner did not
establish that he had the financial resources in August 1998 to
completely satisfy his tax liability at that time. Moreover,
petitioner did not even make a substantial payment toward his tax
liability at that time in order to minimize the further accrual
of interest. Further, once respondent corrected the error and
recomputed petitioner’s liability for interest, petitioner did
not pay off such liability.
In view of the foregoing, we conclude that petitioner’s
third contention is without merit.
D. Conclusion
Consistent with our analysis, we hold that respondent’s
denial of petitioner’s claim for abatement of interest was not an
abuse of discretion.
In order to give effect to our holding,
Decision will be entered
for respondent.
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