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change in petitioner’s address and did not exercise due diligence
in ascertaining petitioner’s correct address.
If petitioner had filed tax returns for 1992 and 1993,
respondent would have been able to assess the taxes petitioner
owed. Sec. 6201(a)(1). Petitioner did not file tax returns for
those years. Therefore, respondent was forced to issue notices
of deficiency for 1992 and 1993.
Petitioner failed to establish that he is entitled to an
abatement of interest. Petitioner has not demonstrated any error
or delay by the Commissioner in performing a ministerial act.
Any delay in sending petitioner a final tax bill for his 1992 and
1993 taxable years was attributable to petitioner’s failure to
file tax returns for those years and to notify the Internal
Revenue Service of his change of address. Accordingly,
respondent did not abuse his discretion in denying petitioner’s
request for interest abatement.
Petitioner offered no evidence to prove entitlement to a
dependency exemption or to head of household filing status, and
these issues are deemed conceded.
To the extent that we have not addressed any of the parties’
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