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from accruing. Petitioners could have paid as early as the date
of the original notices of deficiency in February 2000, or they
could have paid upon settlement of the original Tax Court cases
in October 2000. When petitioners made voluntary payments in May
2001, they could have paid the entire amounts due and requested
refunds in their abatement claims. Finally, petitioners could
have paid when they received their final tax bills in December
2001 and January 2002, respectively. However, petitioners did
not pay the entire amounts due until December 10, 2002.
Petitioners’ delayed payments of their liabilities are not
attributable to error or delay by any officer or employee of the
IRS in performing a ministerial act. Sec. 6404(e)(1)(B).
Because petitioners presented neither authority nor evidence
to support their claim that there were ministerial errors and
delays above and beyond those that had already been identified
and remedied, there was no abuse of discretion in denying an
additional abatement of interest in these cases.
To reflect the foregoing,
Decisions will be entered
for respondent.
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Last modified: May 25, 2011