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period it remained unpaid. See sec. 6601. Even if we were to
assume, arguendo, that petitioner’s delay in paying the 1988
liability was partly attributable to her marital difficulties,
this circumstance would not tend to show that the delay was
attributable to ministerial error or delay by the IRS, as
required for her to establish entitlement to relief pursuant to
section 6404(e).
In sum, we are unable to conclude 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 1988 liability, or that the delay
was not in significant part attributable to petitioner.
Consequently, respondent’s refusal to abate petitioner’s interest
under section 6404 was not an abuse of discretion.
To reflect the foregoing,
Decision will be entered for
respondent.
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