William B. Berry and Marjorie S. Berry - Page 15




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          the basis of what she knew to be incomplete information regarding           
          the taxable year 1983, and (b) IRS employees’ not using the                 
          information provided on the unprocessed amended returns.  It is             
          clear from the record that, although Ms. Parsonson was initially            
          unable to obtain the information from IRS records, she used                 
          information later obtained from petitioners or their accountant             
          in making her settlement computations.  As for the amended                  
          returns, we have already noted that the delay in processing them            
          was not due to any error or delay in performing a ministerial               
          act, but to the ongoing partnership examination.                            
               Accordingly, we find no abuse of discretion in respondent’s            
          failure to abate interest in this case.                                     
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               






















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