John D. and Kim M. Hinterleitner - Page 6

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          result of an employee of the IRS being erroneous or dilatory in             
          performing a ministerial or managerial act.                                 
               Given that petitioners have not established that respondent            
          abused his discretion as to his determination of the disputed               
          interest, we sustain that determination.  To reflect respondent’s           
          concession,                                                                 

                                                  Decision will be entered            
                                             under Rule 155.                          
































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