- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011