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F. Whether Respondent’s Refusal To Abate Interest That Accrued
Other Than From May 1987 to March 1998 Was an Abuse of
Discretion
Petitioners contend that respondent’s failure to abate an
additional $210.98 for 1981 was an abuse of discretion.
Petitioners have not stated the period during which the $210.98
in interest accrued. Petitioners agree that respondent has
abated interest for 1981 from May 1987 to March 1998. The
taxpayer must establish a correlation between the alleged error
or delay by the Commissioner and a specific period for which
interest should be abated as a result of that error or delay.
Donovan v. Commissioner, T.C. Memo. 2000-220. Thus, the $210.98
in interest for 1981 does not relate to respondent’s loss of
petitioners’ 1981-82 amended returns.3
We conclude that respondent’s failure to abate $210.98 in
interest for 1981 was not an abuse of discretion.
To reflect the foregoing,
Decision will be
entered under Rule 155.
3 The $210.98 in interest for 1981 could have accrued
before petitioners filed their amended returns and thus would not
have been abated when respondent abated interest from May 1987 to
March 1998.
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