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the taxpayer in writing with respect to the tax. Wright v.
Commissioner, supra. There can be no abuse of discretion by the
Commissioner for failure to abate interest if the statute that
applies does not give the Commissioner discretion to abate the
interest.
Interest on the interest compounds daily pursuant to section
6622. The interest accruing from May 1, 1999, to the date of
payment was not caused by any delay by the Internal Revenue
Service, is authorized by statute, and is due and owing from
petitioner. The failure to abate that interest was not an abuse
of discretion.
While the Court sympathizes with petitioner’s confusion over
the interest that accrued upon her 1996 tax liability, the tax
was paid 1 year late. It was within the discretion of the
Internal Revenue Service to deny an abatement of interest for the
periods here in question, and that discretion was not exercised
arbitrarily, capriciously, or without sound basis in fact or law.
We hold that respondent did not abuse his discretion in failing
to abate the assessment of interest for the periods April 15,
1997, to and including April 16, 1998, and May 1, 1999, until
paid.
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