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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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