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On May 29, 2000, consistent with the stipulated decision
document entered in each of the docketed cases, deficiencies,
additions to tax, and interest in the following amounts were
assessed:
Year Deficiency Sec. 6651(a) Interest
1986 $ 7,253.00 $147.80 $16,578.00
1987 23,488.00 — 45,545.88
1988 14,044.00 — 22,934.40
1989 5,753.00 — 7,776.27
1991 3,001.12 718.57 3,382.33
On June 27, 2000, respondent received from petitioners a
separate Form 843, Claim for Refund and Request for Abatement,
for each of the underlying years (the abatement claims). Block 5
of the abatement claims is designated “Explanation and additional
claims.” Instructions following the designation direct the
taxpayer to “Explain why * * * this claim should be allowed, and
show computation of tax refund or abatement of interest, penalty,
or addition to tax.” In the space below these instructions on
each of the abatement claims, petitioners inserted the following:
Our 1986 [1987, 1988, 1989, or 1991, as appropriate]
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
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