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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 unfair treatment and impose on us an undue
hardship.
On the abatement claims, petitioners requested abatement of
interest as follows:
Year Period Approximate Amount
1986 02/02/1989 — 10/1999 $13,300
1987 02/02/1989 — 10/1999 25,000
1988 12/16/1991 — 10/1999 16,700
1989 06/10/1991 — 10/1999 10,000
1991 09/13/1993 — 10/1999 2,500
By letter dated January 24, 2001, respondent notified
petitioner that for 1986 and 1987, $295.43 of interest that
accrued from June 8 to July 3, 1989, would be abated, but
otherwise denied each of petitioners’ requests for abatement of
interest. The reason for the partial allowance has not been
provided. By letter dated February 23, 2001, petitioners
requested that respondent’s Appeals Office reconsider the portion
of the abatement claims that had been denied. On February 28,
2001, respondent issued a notice of final determination in which
respondent refused, with the exception previously noted, to abate
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