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time taken by the officers and employees of the Internal Revenue
Service to conduct the examination, appeals and settlement
process was not due to an error or delay in performing a
ministerial act. That being so, it follows that respondent did
not abuse his discretion in denying petitioners' claim for
abatement of interest on Federal income tax deficiencies for 1989
and 1990.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011