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Thereafter, in a Form 1040X, Amended U.S. Individual Income
Tax Return, dated April 11, 1994, petitioner reported an increase
in taxable income of $1,088 (which includes the difference
between her actual and estimated earnings from the law firm) and
a resultant additional income tax liability of $157. No payment
was submitted with the amended return.
On June 30, 1999, petitioner filed a Form 843, Claim for
Refund and Request for Abatement, requesting abatement of
interest on her 1990 Federal income tax liability. Respondent
concluded that the delay in payment of petitioner’s 1990 Federal
income tax liability was not attributable to a ministerial error
on respondent’s part and therefore denied petitioner’s claim in a
notice of final determination dated July 25, 2000.
OPINION
Subject to exceptions not relevant here, interest on an
underpayment of income tax begins to accrue on the due date of
the return for such tax and continues to accrue, compounding
daily, until payment is made. Secs. 6601(a), 6622(a).
The Commissioner may abate the assessment of interest with
respect to a taxpayer’s Federal income tax liability if: (1) The
delay in a payment of such tax is attributable to an official or
employee of the Internal Revenue Service being erroneous or
dilatory in performing a ministerial act after the Internal
Revenue Service has contacted the taxpayer in writing with
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