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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.
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