Joe Nathan Wright and Lola H. Wright - Page 10

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          (including only $5,000 in cash) on each of March 18 and July 19,            
          1996, and $8,600 (including only $2,100 in cash) on October 8,              
          1998.  Apparently, petitioners did not even have enough cash to             
          pay the amounts they had offered in compromise.  Indeed, there is           
          no evidence that petitioners ever paid the balances of their 1993           
          and 1994 tax liabilities.  Petitioners have obviously delayed               
          paying their 1993 and 1994 tax liabilities in full, but the fault           
          lies with them, not with respondent.                                        
          IV.  Conclusion                                                             
               Because the interest at issue is not abatable under section            
          6404(e), respondent necessarily did not abuse his discretion in             
          rejecting petitioners’ request for abatement thereof.                       
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          




















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