Thomas Frederick Dadian and Lois Ann Dadian - Page 19

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        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.                           























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