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whether the Commissioner abused his discretion in declining to
abate any portion of the interest under section 6404. Sec.
6404(h)(1).
None of petitioner’s assertions provide a basis for
respondent to have abated the assessment of interest under
section 6404 with respect to petitioner’s taxable year 1982.
Petitioner’s primary argument in the request for an abatement
seems to have been that he should be credited with interest on a
1982 overpayment from the time the tax was due until the time he
filed his return showing an overpayment, delinquent by nearly 5
years. This argument does not directly address the abatement
issue. We note, however, that a taxpayer is never entitled to
the payment of interest on an overpayment with respect to the
time period preceding the filing of an untimely return. Sec.
6611(b)(3).
Most of petitioner’s other assertions concern the accuracy
of respondent’s deficiency calculations for taxable years 1980,
1981, and 1982, and the appropriateness of respondent’s crediting
a portion of the 1982 overpayment to 1980 and 1981. First, the
accuracy of any deficiency determined by respondent for any such
year is not before this Court. Second, even if respondent should
not have credited the 1982 withholding overpayment to the prior
years because the period of limitations for crediting or
refunding that overpayment has expired, see secs. 6402(a),
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