Joe Nathan Wright and Lola H. Wright - Page 1

                                 T.C. Memo. 2004-69                                   

                               UNITED STATES TAX COURT                                

                JOE NATHAN WRIGHT and LOLA H. WRIGHT, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8200-02.             Filed March 18, 2004.                  

                    Ps submitted multiple offers in compromise with                   
               respect to their reported but unpaid Federal income tax                
               liabilities for 1993 and 1994.  R did not accept any of                
               Ps’ offers.  Ps requested abatement of interest under                  
               sec. 6404(e), I.R.C., on the ground that R unreasonably                
               delayed the processing of their offers in compromise.                  
               R rejected Ps’ request for interest abatement.                         
                    Held:  Ps have failed to establish that any delay                 
               in their payment of their 1993 and 1994 tax liabilities                
               is attributable to any action or inaction on the part                  
               of IRS personnel in processing Ps’ offers in                           
               compromise; therefore, interest is not abatable under                  
               sec. 6404(e), I.R.C., and R did not abuse his                          
               discretion in rejecting Ps’ request for abatement.                     

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