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petitioner as shown in his case activity record, copies of pages
of which were stipulated by the parties.
Petitioner has failed to describe or establish any error or
delay by an officer or an employee of the IRS in performing a
ministerial act that gave rise to assessments of interest on
either deficiencies or payments for his 1990 and 1991 taxable
years. The Court therefore holds that respondent’s failure to
abate interest was not an abuse of discretion.
The Court has considered all other arguments advanced by
petitioner, and, to the extent not discussed above, has found
those arguments to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011