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with regard to the 1988 tax year providing for an overpayment of
$2,194.
Interest Abatement Claim for 1981
On June 27, 1996, petitioners filed a Request For Abatement
Of Interest (interest abatement claim) with respondent. In the
interest abatement claim, petitioners stated that “due to the
appearance that there was a realistic possibility of substantial
refund for 1985 with interest in an amount sufficient to pay all
of the * * * [1981] remaining liability, Problem Resolution
agreed that the case would be placed on hold.” Petitioners
asserted that the “1988 audit, however, became a substantial
comedy of delays.” Petitioners alleged that the audit of the
1988 tax year was neither performed adequately nor timely. As a
result, petitioners argued:
Had the 1988 audit been completed in a reasonable
manner, the tax refunds that would have discharged the
liability, or the lack thereof, would have * * *
adequately determined the manner in which Mr. Wish
could have and would have paid the entire liability
including interest. As of a matter of fact, as soon as
the liability was determined, Mr. Wish made a
substantial payment on the balance of the income tax
liability.
Respondent found no errors or delays to support an abatement of
interest and therefore denied petitioners’ interest abatement
claim.
OPINION
Section 6404(e)(1) provides that the Commissioner may abate
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