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pursuant to section 6404(h).1 The issue for decision is whether
respondent abused his discretion in failing to abate interest on
petitioner’s Federal income tax liabilities for 1989 and 1990.
We hold that he did not.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing of
the petition, petitioner resided in Hixson, Tennessee.
In June 1994, petitioner was informed by letter that his
1992 Federal income tax return had been selected for examination.
The letter also requested certain documents, including
petitioner’s 1991 and 1993 Federal income tax returns. Later
that month, petitioner had lengthy meetings with the revenue
agent who was conducting the examination. The revenue agent went
on maternity leave 2 months later.
In September 1994, petitioner filed amended Federal income
tax returns for 1991, 1992, and 1993, reporting additional
taxable income of $173,817, $191,595, and $63,628, respectively.
1 Unless otherwise indicated, all section references are to
the applicable provision of the Internal Revenue Code for the
periods involved, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
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