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that occurs during the processing of a taxpayer’s case after all
prerequisites to the act, such as conferences and review by
supervisors, have taken place.” Sec. 301.6404-2T(b)(1),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 30163 (Aug. 13,
1987). The final regulations under section 6404(e), which were
issued on December 18, 1998, generally effective with respect to
interest accruing on deficiencies or payments of tax for taxable
years beginning after July 30, 1996, provide the same definition.
Sec. 301.6404-2, Proced. & Admin. Regs. The final regulations
note that a managerial act is “an administrative act that occurs
during the processing of a taxpayer’s case involving the
temporary or permanent loss of records or the exercise of
judgment or discretion relating to management of personnel."
Sec. 301.6404-2(b)(1), Proced. & Admin. Regs.
We review for abuse of discretion the Commissioner’s
determination denying an abatement of interest. See sec.
6404(i); Lee v. Commissioner, 113 T.C. 145, 149 (1999). We find
no abuse of discretion here. Petitioners have not established
any unreasonable error or delay on behalf of the Commissioner in
performing a ministerial or managerial act that occurred before
June 1, 2000. In fact, the record indicates that the interest
accruals before June 1, 2000, were merely the result of
petitioners’ failure to pay the entire balance owed, and not the
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