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agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: On February 7, 2000,
respondent issued a notice of final determination denying
petitioners’ request for an abatement of interest under section
6404(e)(1) for their 1993, 1994, and 1995 tax years. The issue
for decision is whether respondent abused his discretion in
failing to abate the assessment of interest.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. All references to
petitioner are to Robert A. Strang. At the time this petition
was filed, petitioners resided in Punta Gorda, Florida.
Petitioner is a certified public accountant. On December
21, 1995, respondent began an examination of Sunshine Travel
Agency, Inc.’s (Sunshine) corporate tax returns for a period
unspecified in the record. Sunshine is wholly owned by
petitioners. On January 18, 1996, Internal Revenue Service (IRS)
Agent Karen Garner held her first meeting with petitioner. Agent
Garner expanded her examination to include petitioners’ 1993 and
1994 individual income tax returns on January 23, 1996. Between
March 1996 and June 1997, Agent Garner spent at least 48 days
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