- 24 - in support of her position that the delay in the payment of her unpaid liability for each of the years 1987, 1988, and 1989 was attributable to respondent’s being erroneous or dilatory in performing a ministerial act. Respondent contends that a signif- icant aspect of petitioner’s delay in the payment of her unpaid liability for each of those years is attributable to petitioner. On the record before us, we agree with respondent. At all times, petitioner had the ability to stop the accrual of interest on her unpaid liability for each of the years 1987, 1988, and 1989 by paying that liability. On the record before us, we find that petitioner has failed to show that the delay in the payment of her unpaid liability for each of the years 1987, 1988, and 1989 was attributable to respondent’s being erroneous or dilatory in performing a ministerial act. On that record, we further find that petitioner has failed to show that respondent abused respon- dent’s discretion in determining not to abate interest during the period 1990 to present with respect to each of those years. We have considered all of petitioner’s arguments and conten- tions that are not discussed herein, and we find them to be without merit and/or irrelevant. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011