Robert A. and M. Faye Strang - Page 2

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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.                                
               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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