- 9 - the docketed cases, find nothing out of the ordinary in either the sequence of events or the passage of time between events. Moreover, petitioners acknowledge, as evidenced by the above- quoted passages, that the length of time that the docketed cases were pending is not attributable to the erroneous or dilatory performance of a ministerial act by respondent’s employee. See Lee v. Commissioner, supra. Resolution of the docketed cases was obviously delayed to allow for the enactment of the proposed legislation, and the delay resulted in the imposition of interest. We are not unsympathetic to petitioners’ situation and the frustration that must have followed their failed attempts to resolve their tax disputes through legislation long promised but never enacted. Nevertheless, under the circumstances, the additional interest that accrued during the period of delay of the docketed cases is not subject to abatement under section 6404(e). Simply put, the interest that accrued on petitioners’ Federal income tax liabilities for the underlying years results from petitioners’ failure to pay their Federal income tax liability for each year when due. Section 6404(e) does not authorize the abatement of interest upon that ground, and respondent’s refusal to do so is not an abuse of discretion. See Donovan v. Commissioner, T.C. Memo. 2000-220; Douponce v. Commissioner, T.C. Memo. 1999-398.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011