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applied the proceeds of the second levy to petitioner’s
undisputed tax liabilities for subsequent tax years. Petitioner
was not assessed any additional interest for 1993.
Respondent chose not to abate interest because petitioner’s
1993 tax liability was resolved by the first levy, and the
proceeds from the second levy were applied to petitioner’s
outstanding tax liabilities for subsequent years. Respondent’s
decision not to abate interest was not arbitrary, capricious, or
without sound basis in fact or law. Accordingly, we hold that
respondent’s denial of petitioner’s claim to abate interest was
not an abuse of discretion.
Decision will be entered for
respondent.
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