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respondent, during his consideration of their request, that they
were relying on allegations 8, 9, and 10 as additional grounds
for relief. As we are charged with determining whether
respondent abused his discretion in denying petitioners’ request
for interest abatement, allegations petitioners failed to bring
to respondent’s attention during that consideration process
generally cannot be relevant to our inquiry. See Stewart v.
Commissioner, T.C. Memo. 2003-106 n.5; cf. Magana v.
Commissioner, 118 T.C. 488, 493 (2002) (“it would be anomalous
and improper for us to conclude that respondent’s Appeals Office
abused its discretion under section 6330(c)(3) [collection due
process determination] in failing to grant relief, or in failing
to consider arguments, issues, or other matter not raised by
taxpayers or not otherwise brought to the attention of
respondent’s Appeals Office”). Accordingly, we need not further
evaluate those allegations.
B. Allegations 1-7
Accepting arguendo the veracity of the allegations numbered
1-7 above and that such allegations involve “ministerial acts”
for purposes of section 6404(e), we conclude that petitioners
have failed to demonstrate that respondent abused his discretion
in refusing to abate interest with respect to petitioners’ 1993
and 1994 tax liabilities. We reach that conclusion primarily
because petitioners have failed to establish that they were
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