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the “Asia Financial Crisis”, which according to him started on
October 23, 1997, at much higher prices and paid the tax due is
irrelevant to our consideration.5
Consequently, respondent’s refusal to further abate
interest was not an abuse of discretion. We have considered
all other arguments advanced by petitioner, and to the extent
not discussed above, have found those arguments to be
irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
5 We note that petitioner agreed to the tax deficiencies
and penalties for his 1992 and 1993 tax years in August of 1997,
before the start of the financial crisis in Asia, which
petitioner alleges caused him to pay his tax liabilities in
installments. Petitioner chose to continue to speculate in the
Hong Kong Stock Exchange until he received his final statements
of account and bills for those tax years.
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