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Our 1989 return was audited, brought to the Appeals
Office, and in Tax Court. We have a good faith belief
that delays occurred in preforming [sic] ministerial
acts by an officer or employee of the Internal Revenue
Service during that period. The occurance [sic] of
such delays requires the abatement of the assessment of
interest for those particular periods. Furthermore,
throughout much of this period legislation was pending
which would have substantially affected the treatment
of specific deductions. Accordingly, the Service
postponed consideration of these matters. Further, a
death in the family of our legal counsel resulted in an
additional delay in consideration of our case. In
light of the ministerial delays, and as well as our
reliance on the actions of Congress, the failure to
abate interest in our circumstances would constitute
grossly unfiar [sic] treatment and impose on us an
undue hardship.
Elsewhere on the abatement claim, petitioners indicate that the
amount to be “refunded or abated” is “approximately [$]2,400”.
In the area designated “Period--prepare a separate Form 843 for
each tax period”, petitioners entered “from March 8, 1993 to
October, 1999.” Try as we have, we are unable to appreciate the
relevance of this period to the relief requested by petitioners
either in the abatement claim or in this proceeding. Block 4a of
the abatement claim provides for a check-the-box entry if the
request is for abatement or refund of “interest caused by IRS
errors or delays”. This box is left blank, as is the following
area where the “dates of payment” should have been inserted.
Despite its many infirmities, respondent considered the
abatement claim as a request for abatement of all interest that
had accrued with respect to petitioners’ 1989 Federal income tax
liability. As earlier noted, with the exception of $8.61, all of
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