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the limited partners on August 14, 1995, it was necessary to wait
several months to see how many partners would accept the offer
before respondent could send FPAA's to the limited partners who
rejected the settlement. At that point, after the settlement
letters were mailed, the speed at which the matter was to be
closed was up to the partners. The Geises never signed a Form
870-P(AD), and respondent did not receive the Jacobses' Form 870-
P(AD) until July 11, 1996. From May until July 1996, when
respondent sent the FPAA's to petitioners, Appeals Officer
Thurston prepared the documents to be included in the FPAA
package. On the basis of the foregoing, we conclude that there
were no errors or delays in the performance of ministerial acts
by respondent's officers or employees during that period.
Accordingly, we uphold respondent's final determination not to
abate interest from April 22, 1994, through July 8, 1996.
To reflect the foregoing,
Decisions will be entered
abating interest for the period
of time stated herein.
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