- 4 - 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011