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partnership proceeding notices from the IRS). The failure to
give such notices, therefore, is not an error requiring abatement
of interest.
Although it may provide no comfort to petitioner, the delays
experienced in processing her case were not unusual during the
period from 1984 to 1992. A large number of tax shelter cases
were filed in this Court during the late 1970s and early 1980s as
a result of tax shelter programs such as those promoted by
Swanton. The large number of cases led to specialized responses
by the IRS, by the Court, and by Congress. The response of
Congress included the increased rate of interest accruing under
former section 6621(c) applicable to deficiencies attributable to
tax-motivated transactions, as explained in H. Rept. 98-861, at
985-986 (1984), 1984-3 C.B. (Vol. 2) 239-240:
The provision is effective with respect to
interest accruing after December 31, 1984, regardless
of the date the return was filed.
The conferees note that a number of the provisions
of recent legislation have been designed, in whole or
in part, to deal with the Tax Court backlog. Examples
of these provisions are the increased damages
assessable for instituting or maintaining Tax Court
proceedings primarily for delay or that are frivolous
or groundless (sec. 6673), the adjustment of interest
rates (sec. 6621), the valuation overstatement and
substantial understatement penalties (secs. 6659 and
6661), and the tax straddle rules (secs. 1092 and
1256). * * *
The conferees believe that, with this amendment,
the Congress has given the Tax Court sufficient tools
to manage its docket, and that the responsibility for
effectively managing that docket and reducing the
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