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processed, petitioners were mailed examination workpapers for
1982 and 1983, and assessments of additional tax and interest for
those years were made against petitioners on March 24, 1997.
From about March through August 1997, petitioners and the IRS
corresponded with respect to that tax liability.
On the basis of the foregoing, we conclude that there were
no errors or delay in the performance of ministerial acts by
respondent’s officers or employees from October 23, 1995, through
August 1997.
Conclusion
A careful review of the record in this case fails to
disclose any erroneous or dilatory performance of a ministerial
act by an officer or employee of respondent with respect to
respondent’s processing of adjustments to petitioners’ 1982 and
1983 individual income tax returns. Consequently, we hold that
respondent’s denial of petitioners’ claim for abatement of
interest that accrued from December 31, 1988, through August 1997
with respect to deficiencies resulting from the Blue Gem
partnership audit was not an abuse of discretion.
To reflect all of the above,
Decision will be entered
for respondent.
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