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officer or employee of the IRS being erroneous or dilatory in
performing a ministerial act.” Lee v. Commissioner, 113 T.C.
145, 148 (1999). Petitioner has not alleged a ministerial error
or delay within the meaning of section 6404(e). Furthermore, the
evidence does not establish that respondent committed a
ministerial error or delay requiring an abatement of interest.
Section 6404(g) is effective only for tax years ending after
July 22, 1998. Nerad v. Commissioner, T.C. Memo. 1999-376.
Consequently, section 6404(g)(1) is inapplicable because
petitioner is seeking an abatement of interest on his income tax
liability for the taxable year 1995.
In reaching our holdings herein, we have considered all of
petitioner’s arguments, and, to the extent not mentioned above,
we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011