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be used sparingly, and it did not intend that abatement “be
used routinely to avoid payment of interest.” Id.
Petitioner currently argues that his interest should be
abated because he counted on receiving a tax "credit" of $5,717
from 1983 toward the payment of his 1980 tax deficiency in
accordance with written and oral advice he received from
"several" IRS employees prior to filing a petition in the Tax
Court. He states now that he would have returned the $6,330
check, which he at one time claimed he did not receive, but for
the "erroneous" advice given to him.
Petitioner's statement of the facts in his case has evolved
to its present form. From October 1989 until April of 1993,
petitioner represented to respondent that he had not received
the $6,330 refund he had requested on Form 1045. After signing
a decision document agreeing that there were deficiencies in
his Federal income taxes for 1980 and 1983, he formulated a new
position. His new position is that it was the fault of the IRS
that he received the $6,330 refund "in error". Furthermore, he
now states that he sought a redetermination of his deficiencies
only because several persons at IRS told him that he had a tax
"credit" of $5,717 that would be deducted from the $6,330
refund if he lost his case in Court.
Petitioner has presented no evidence of the "advice" he
claims he received from IRS employees, other than his own
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