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petitioner responded by letter on July 8, 1998.
On the record before us, we find that petitioner has failed
to show that respondent abused respondent’s discretion in deter-
mining in the notice of determination to proceed to collect the
additions to tax under section 6651(a)(1) and (2) that respondent
assessed with respect to each of petitioner’s taxable years 1987,
1988, and 1989.9
Interest
We construe petitioner’s position with respect to the
interest at issue as a request to review respondent’s failure to
abate interest under section 6404(e). See supra note 4. We have
jurisdiction to review respondent’s determination in the notice
of determination not to abate interest. Sec. 6404(i); Katz v.
Commissioner, 115 T.C. 329, 340-341 (2000).
Petitioner contends that respondent abused respondent’s
discretion in failing to abate interest on petitioner’s unpaid
liability for each of the years 1987, 1988, and 1989 because:
respondent * * * has performed a ministerial act re-
9With respect to petitioner’s contention that she would be
penalized if the Court were to allow respondent to proceed to
collect the additions to tax at issue under sec. 6651(a)(1) and
(2), we note that additions to tax such as those under sec.
6651(a)(1) and (2) are remedial, and not punitive. See Helvering
v. Mitchell, 303 U.S. 391, 401 (1938); Ianniello v. Commissioner,
98 T.C. 165, 187 (1992). Such additions to tax are provided
primarily as a safeguard for the protection of the revenue and to
reimburse the Government for the significant expense of investi-
gation and the loss resulting from a taxpayer’s actions or
omissions. See Helvering v. Mitchell, supra.
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