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interest for 1981 resulting from R’s denial of Ps’
White Rim deductions.
Held: R’s loss of Ps’ 1981-82 amended returns
from May 1987 to March 1998 was a ministerial error for
purposes of sec. 6404(e), I.R.C.
Held, further, R’s refusal to abate interest that
accrued from May 1987 to March 1998 on Ps’ tax
liability for 1980 was an abuse of discretion.
Held, further, R’s refusal to abate interest that
accrued other than from May 1987 to March 1998 was not
an abuse of discretion.
Kenneth R. Cohen, for petitioners.
Shawna A. Early, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent issued a final determination
disallowing petitioners’ claim under section 6404(e) for
abatement of interest related to petitioners’ 1980 and 1981 tax
years. Petitioners timely filed a petition under section
6404(g)1 and Rule 280.
The issue for decision is whether respondent’s denial of
petitioners’ request to abate interest relating to petitioners’
1 This was redesignated sec. 6404(i) by the Internal
Revenue Service Restructuring and Reform Act of 1998, Pub. L.
105-206, secs. 3305(a), 3309(a), 112 Stat. 743, 745. Sec.
6404(i) was later redesignated sec. 6404(h) by the Victims of
Terrorism Relief Act of 2001, Pub. L. 107-134, sec. 112(d)(1)(B),
115 Stat. 2435 (2002).
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