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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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