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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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