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claims to abate interest on income tax liabilities for 1995
pursuant to section 6404(e). The issue for decision is whether
the failure to abate the additional interest was an abuse of
discretion.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Runnells, Iowa, at the time that they
filed their petitions in these cases.
Dan F. Bartelma (Dan) and James Richard Bartelma (James)
were equal general partners in Bartelma Farm Partnership (the
partnership). They were also shareholders, along with other
family members, in Bartelma Farms, Inc. The partnership timely
filed its Form 1065, U.S. Partnership Return of Income, for 1995.
Petitioners timely filed their individual income tax returns for
1995.
On May 9, 1997, petitioners were notified that the
partnership’s Form 1065 for 1995 was assigned for examination.
Petitioners met with an agent of the Internal Revenue Service
(IRS), Matthew M. McKenney (McKenney), on May 27, 1997, and
received the examination results in a letter dated July 14, 1997.
The examination resulted in adjustments to the partnership’s
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