Laurence L. and Patricia Jacobs - Page 22




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          inquiry in response to the request.  We do not believe that                 
          Congress had that kind of review process in mind when it enacted            
          section 6404 and provided this Court jurisdiction in section                
          6404(i) to review, for abuse of discretion, the Commissioner's              
          determination not to abate interest.  Accordingly, because                  
          respondent has failed to explain clearly the basis for                      
          respondent's refusal to abate interest for the period September             
          1, 1987, through April 3, 1989, and the period November 1, 1989,            
          through November 17, 1991, we hold that it was an abuse of                  
          discretion for respondent to refuse to abate interest for that              
          period.  For the period April 4, 1989, through September 30,                
          1989, we uphold respondent's final determination not to abate               
          interest.                                                                   
          November 18, 1991, Through July 8, 1996                                     
               From November 18, 1991, through the mid-May 1993, there were           
          no ministerial acts performed by respondent.  On March 19, 1992,            
          Appeals Officer Thurston began her work resolving the disputed              
          issues.  Much of her early work with the TLP case depended upon             
          the cooperation of TLP's representatives in scheduling meetings             
          and phone conferences as well as providing her with a paper                 
          outlining TLP's position on the substantive issues.  Most of the            
          delay that occurred during that period of time was due to delay             
          caused by Mr. Reising.  His tardiness in completing TLP's                   
          position paper was the cause of significant delay.  Accordingly,            






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