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processing of the 1981 tax return. See sec. 301.6404-2T(b)(1),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 30162, 30163 (Aug.
13, 1987). Finally, respondent argues that the accrual of
interest during the period in issue is solely attributable to
petitioners’ decision to seek a hold (based on the claim for
refund) on collection and not to pay the outstanding tax
liability.
In the instant case, petitioners have not specifically
addressed upon which prong of section 6404(e)(1) they base their
claim. In enacting section 6404(e)(1)(A), Congress vested the
Commissioner with discretion to abate interest on any deficiency
attributable in whole or in part to an error or delay committed
by an officer or employee of the IRS in performing ministerial
acts. For example, Congress explained that “a delay in the
issuance of a statutory notice of deficiency after the IRS and
the taxpayer have completed efforts to resolve the matter could
be grounds for abatement of interest.” S. Rept. 99-313, at 209
(1986), supra at 209. Petitioners have not alleged that
respondent committed any errors or delays in determining or
assessing petitioners’ tax deficiency with regard to the 1981 tax
year.
Errors or delays in the determination or assessment of a
deficiency, however, do not constitute the sole basis for relief
under section 6404(e). Congress has also provided relief for any
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