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deficiencies from the time they were due until they were paid.
Petitioner seeks review of respondent’s refusal to abate
interest.4
Discussion
Petitioner argues that the interest on the reduced
deficiencies should be abated because respondent wrongfully
refused to postpone and transfer the initial audit to May 1995 in
California, and because respondent is responsible for all delays
after May 1995 in reconsidering the assessment.
Petitioner also objects in his responses to respondent’s
motion for summary judgment, contending that summary judgment is
an unfair procedure because it is “not a mechanism for presenting
my case and on top of that it is not a forum I ever agreed to.”
Petitioner wants a trial so that he can call or force respondent
to call as witnesses various Internal Revenue Service employees
with whom he had contact both in Pennsylvania and California, and
can compel respondent to produce a “short list” of 20 categories
of documents, including personal records of respondent’s
auditors, respondent’s auditor and employee hiring guidelines and
training programs, the results of all customer satisfaction
4The parties have not made clear what is the amount in
dispute. It appears to us that the total amount in dispute is
less than $1,000, consisting of interest on the agreed
deficiencies of approximately $1,600 from, at the earliest, May
1995 (when petitioner first wanted the audit to be held) until
petitioner paid the deficiencies in 2000.
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