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petitioners are referring to the period from April 2, 1991,
through January 28, 1993. The IRS auditor completed his work
with respect to Madison Leasing on April 2, 1991, but the
proposed FPAA for Madison Leasing was not submitted for approval
until January 28, 1993. Initially, we note that we cannot find
an abuse of discretion in respondent’s failure to abate interest
for any period before January 1, 1992, because petitioners did
not request that respondent exercise his discretion and abate
interest accruing before that date. As for the remainder of this
period, it is clear from the letters which petitioners received
from CIGNA that during this time the IRS was working on resolving
cases involving Madison Leasing and the related partnerships.
The letters, which petitioners were receiving at least as late as
October 29, 1991, indicate that current progress was being made
toward settling docketed cases and beginning work on settlements
for nondocketed cases. In addition, the May 7, 1992, letter from
Coopers & Lybrand to CIGNA indicates progress on the settlements
was ongoing. Thus, even for this period the evidence in the
record shows continuing progress.
Finally, petitioners point to three specific causes of
delay, though without correlating the causes with any specific
timeframe for abatement. First, petitioners argue that delays
were caused by the IRS’s refusal to provide the settlement offer
when petitioners initially requested it. As noted above, a
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