- 19 - F. July 20, 1999, Through February 9, 2000 After the South Bay closing agreement was countersigned, respondent adjusted petitioners’ 1984 return according to the terms of the closing agreement and, on February 9, 2000, issued petitioners the notice of adjustment. Respondent followed regular IRS procedures in the processing of petitioners’ notice of adjustment. Petitioners have not shown that respondent was dilatory in performing a ministerial act during this period. We hold that it was not an abuse of discretion for respondent to deny petitioners’ request for interest abatement for the period July 20, 1999, through February 9, 2000. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011