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discretion in failing to abate the assessment of interest with
respect to petitioner’s 1994 tax year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. On the date the petition
was filed, petitioner resided in Aurora, Colorado.
Petitioner is a tax return preparer and has prepared tax
returns since 1990.
Petitioner and her spouse, Hamidou Diarra (Mr. Diarra),
timely filed a 1994 Federal income tax return with a filing
status of “Married filing joint return.” On February 26, 1997,
respondent issued a notice of deficiency for 1994 determining a
deficiency of $8,919 and an accuracy-related penalty under
section 6662(a) of $1,784. Petitioner filed a petition with the
Court disputing the notice of deficiency. Respondent assessed
the deficiency on Mr. Diarra using nonmaster file procedures
because Mr. Diarra did not petition the Court.2
During the course of the trial, the parties reached a
settlement. Respondent recited the terms of the settlement on
2 Nonmaster file accounts are created as a routine matter
when an action is taken that affects only one spouse on an
account that originally is on a master file jointly; i.e., only
one spouse petitions the Court. 4 Administration, Internal
Revenue Manual (CCH), secs. 8.17.3.1.5 and 8.17.3.1.6 at 27,802
and 27,803.
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