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respondent's determination not to abate interest. There may
simply be no record of what happened after the case was sent to
Quality Review and no witness who can explain what happened. On
the other hand, it is possible that respondent performed an
inquiry yielding useful information but failed to offer that
information to petitioners or to the Court. In any event, except
for the period April 4, 1989, through September 30, 1989, the
period of time the TLP case was back with Agent McBrien's
examination group, we can only speculate, as respondent does, as
to what happened with the TLP file during the period from
September 1, 1987, through November 17, 1991.
Because section 6404(e) provides for this Court to review
for abuse of discretion the Commissioner's determination as to
whether interest will be abated, the Court must decide how to
proceed where the basis for the Commissioner's determination has
not been clearly explained either in the final determination
letters or at trial. In Motor Vehicle Manufacturers Association
of the United States v. State Farm Mut. Auto. Ins. Co., 463 U.S.
29, 49 (1983), the Supreme Court stated that an agency must
cogently explain why it has exercised its discretion in a given
manner. Similarly, in National Treasury Employees Union v.
Federal Labor Relations Auth., 802 F.2d 843, 845 (6th Cir. 1986)
(citing Ross Express, Inc. v. United States, 529 F.2d 679, 682
(1st Cir. 1976)), the Court of Appeals for the Sixth Circuit
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