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(7th Cir. 1995); Bax v. Commissioner, 13 F.3d 54, 58 (2d Cir.
1993); Asciutto v. Commissioner, T.C. Memo. 1992-564, affd. per
order 26 F.3d 108 (9th Cir. 1994). Petitioners also do not
qualify for an abatement of interest under the applicable version
of section 6404(e)(1). Such an abatement requires the occurrence
of a “ministerial act”, and the revenue agent’s disregard of
section 6601(d)(1) results not from a ministerial act but from a
misapplication of Federal tax law. See sec. 301.6404-4(b)(1) and
(2), Proced. & Admin. Regs.
In sum, we hold for respondent as to all of the substantive
matters in dispute. In so doing, we have considered all
arguments made by the parties and have found those arguments not
discussed herein to be irrelevant and/or without merit.
Accordingly,
Decision will be
entered for respondent.
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