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garding my case under the law.
* * * * * * *
* * * Respondent has delayed my tax situation and did
not allow me due process or accurate information until
I sought relief from the Court. This was an abuse of
their discretion. * * *
Section 6404(e) provides in pertinent part:
SEC. 6404. ABATEMENTS.
(e) Assessments of Interest Attributable to Errors
and Delays by Internal Revenue Service.--
(1) In general.--In the case of any assess-
ment of interest on--
* * * * * * *
(B) any payment of any tax described in
section 6212(a) to the extent that any error
or delay in such payment is attributable to
such officer or employee [of the Internal
Revenue Service] being erroneous or dilatory
in performing a ministerial act,
the Secretary may abate the assessment of all or
any part of such interest for any period. For
purposes of the preceding sentence, an error or
delay shall be taken into account only if no sig-
nificant aspect of such error or delay can be
attributed to the taxpayer involved, and after the
Internal Revenue Service has contacted the tax-
payer in writing with respect to such * * * pay-
ment.[1]
1Sec. 6404(e) was amended by Taxpayer Bill of Rights 2, Pub. L. 104-168,
sec. 301, 110 Stat. 1452, 1457 (1996), to permit the Secretary to abate
interest with respect to an “unreasonable” error or delay resulting from
“managerial” and ministerial acts. This amendment applies to interest
accruing with respect to deficiencies or payments for taxable years beginning
after July 30, 1996; therefore, it does not apply to the instant case. Katz
v. Commissioner, 115 T.C. 329, 341 n.18 (2000).
Petitioner does not point to any ministerial act performed
by respondent or otherwise advance any arguments or contentions
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