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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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Last modified: May 25, 2011