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we uphold respondent's final determination not to abate interest
from November 18, 1991, through mid-May 1993. By the time
Appeals Officer Thurston received TLP's position paper, she was
set to go to training for approximately 6 weeks--from
approximately mid-May through early July 1993. The case was not
reassigned to another agent while Appeals Officer Thurston was in
training, and no work was completed on the TLP case. Pursuant to
section 301.6404-2T(b), Example (4), Temporary Proced. & Admin.
Regs., 52 Fed. Reg. 30163 (Aug. 13, 1987), however, the decision
not to reassign the case while Appeals Officer Thurston was in
training was not a ministerial act. Accordingly, from mid-May
through early July 1993, the period of time Appeals Officer
Thurston was in training, we uphold respondent's final
determination not to abate interest.
When Appeals Officer Thurston returned from training she
finished her response to Mr. Reising's position paper. By that
time, the focus of the appeal switched to how the individual
partners would be treated. Discussions regarding the treatment
of the individual limited partners continued until September 16,
1993, eventually ending with the understanding that there would
not be individual settlements for each of the limited partners.
Because there were no delays caused by any ministerial acts of
respondent's officers or employees from early July through
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