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has contacted the taxpayer in writing with respect to the
deficiency and (2) if no significant aspect of the error or delay
is attributable to the taxpayer. See sec. 6404(e)(1); Krugman v.
Commissioner, 112 T.C. 230, 239 (1999); Nerad v. Commissioner,
T.C. Memo. 1999-376. Section 6404(e)(1) “does not therefore
permit the abatement of interest for the period of time between
the date the taxpayer files a return and the date the IRS
commences an audit, regardless of the length of that time
period.” H. Rept. 99-426, at 844 (1985), 1986-3 C.B. (Vol. 2) 1,
844; S. Rept. 99-313, at 208 (1986), 1986-3 C.B. (Vol. 3) 1, 208.
Congress did not intend for section 6404(e) to be used
routinely. Accordingly, we order abatement only “where failure
to abate interest would be widely perceived as grossly unfair.”
Lee v. Commissioner, supra at 149; H. Rept. 99-426, supra at 844,
1986-3 C.B. (Vol. 2) at 844; S. Rept. 99-313, supra at 208, 1986-
3 C.B. (Vol. 3) at 208.
As we understand her argument, petitioner contends that
respondent’s failure to examine her income tax returns for 1988
through 1992 caused her to claim the same type of deductions, for
which there was no basis in law, on her income tax returns for
1993, 1994, and 1995. Accordingly, in petitioner’s view,
interest on the deficiencies in income taxes for 1993, 1994, and
1995 should be abated because that interest is attributable to
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