- 19 -
not establish error or delay by the Commissioner in performing a
ministerial act. Lee v. Commissioner, supra at 150. The Court,
therefore, concludes that the passage of 19 months during the
audit of petitioners' 1995 tax year is not attributable to error
or delay in performing a ministerial act.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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