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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.
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