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See also Hirshfield v. United States, 88 AFTR 2d 2001-6236, 2001-
2 USTC par. 50,480 (S.D.N.Y. 2001); cf. Sainte-Yves v.
Commissioner, T.C. Memo. 2002-158. Consequently, the
requirements of section 6224(c) do not apply to concessions
involving interest abatement. Cinema ‘84 v. Commissioner, 294
F.3d 432, 439-440 (2d Cir. 2002), affg. 111 T.C. 198 (1998);
Sainte-Yves v. Commissioner, supra. Therefore, section 6224 does
not require respondent to offer the same terms regarding interest
abatement to petitioner that were offered to Mrs. Beagles.
We review respondent’s actions for abuse of discretion.
Petitioner argues that respondent abused his discretion because
he did not offer the same terms to him as were offered to Mrs.
Beagles. Petitioner’s position is inconsistent with the
principle that respondent reviews each case in light of its
specific facts and circumstances. However, if respondent’s
actions with respect to petitioner’s settlement violated the duty
of consistency, which has been recognized by this Court in other
contexts, there is a potential for abuse of discretion.
As stated above, the importance of consistency of tax
compromises has been previously recognized by this Court. Penn-
Field Indus., Inc. v. Commissioner, 74 T.C. 720, 722 (1980);
Fresoli v. Commissioner, T.C. Memo. 1988-384; Avers v.
Commissioner, T.C. Memo. 1988-176. However, this duty must be
balanced against the settlement discretion given to the IRS,
which is “at its heart a discretion to treat similarly situated
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