Robert B. Kemp, Jr. - Page 14

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          did not constitute a delay in the performance of a ministerial              
          act, comport with our conclusion that no ministerial delay                  
          occurred in these circumstances.  Moreover, the parties’                    
          stipulations and the accompanying exhibits demonstrate that                 
          respondent’s issuance of the notice of deficiency in question was           
          not a dilatory ministerial act, as petitioner claims.  In sum,              
          petitioner has not shown any abuse of discretion on the ground              
          that respondent failed to provide reasons for his decision not to           
               We have considered all other contentions raised by                     
          petitioner and conclude that they lack merit.                               
               For the foregoing reasons, respondent’s refusal to abate any           
          interest with respect to petitioner’s 1989 and 1990 deficiencies            
          was not an abuse of discretion.  To reflect the foregoing,                  

                                             Decision will be entered for             

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