- 8 - 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 werePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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