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correctly determined because of petitioner’s involvement in a
tax-motivated transaction.
On August 14, 2000, respondent issued petitioner a final
determination letter disallowing petitioner’s request for
interest abatement for the tax years 1982 through 1987.
Respondent based the disallowance on the fact that no errors or
delays that merit interest abatement were discovered in
respondent’s review of available records and other information.
Respondent informed petitioner that he could file a Tax Court
petition for a review of respondent’s denial of interest
abatement if he disagreed with the final determination.
OPINION
A. The Commissioner’s Authority To Abate Interest
In general, interest on an underpayment of income tax begins
to accrue on the due date of the return for the tax and continues
to accrue, compounded daily, until payment is made. See secs.
6601(a), 6622(a).
Pursuant to section 6404(e)(1), as it applies in this case,
the Commissioner may abate the assessment of interest on: (1)
Any deficiency attributable to any error or delay by an officer
or employee of the IRS in performing a ministerial act, or (2)
any payment of any tax described in section 6212(a) to the extent
that any error or delay in payment is attributable to the
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