Thomas R. Camerato - Page 6




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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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