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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
abate.
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
respondent.
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