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that the final outcome of this more protracted administrative
proceeding would have been any more in petitioner’s favor.
Accordingly, there is no basis to conclude that any of the
interest on petitioner’s 1995 deficiency was attributable to the
group manager’s failure to meet with petitioner.
In sum, the record does not show that there was any
erroneous or dilatory performance of a ministerial act by
respondent that caused or contributed to the delay in
petitioner’s payment of the 1995 tax liability. Consequently,
respondent’s denial of petitioner’s request to abate interest
under section 6404 was not an abuse of discretion.
Decision will be entered
for respondent.
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Last modified: May 25, 2011