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When computing those liabilities, respondent did not allow as
itemized deductions the property taxes originally deducted by
petitioners on their Schedules F. Even assuming that this was a
ministerial act, for purposes of interest abatement, respondent’s
error must have contributed to errors or delays in petitioners’
payment of the liabilities. See sec. 6404(e)(1); see also
Hawksley v. Commissioner, T.C. Memo. 2000-354; Douponce v.
Commissioner, T.C. Memo. 1999-398.
The record indicates that respondent’s original disallowance
of deductions for the property taxes had no effect on
petitioners’ payment of their income tax liabilities.
Petitioners have never attempted to pay any portion of the
liabilities, nor do petitioners contend that they would have paid
had they known earlier the correct amount. Moreover, once
petitioners learned of the correct total of their income tax
liabilities during discussions of the Rule 155 computation,
petitioners still made no payment attempts and even disputed the
deficiency amounts on their Form 843. Accordingly, we conclude
that any delays in petitioners’ payment of their income tax
liabilities were not attributable to any error by respondent in
performing a ministerial act and that respondent’s denial of
petitioners’ claim for abatement of interest was not an abuse of
discretion.
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