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taxpayer in writing about the deficiency or payment, and
(b) the taxpayer did not contribute significantly to the
error or delay. Congress intended for the Commissioner to
abate interest under section 6404(e) "where failure to
abate interest would be widely perceived as grossly unfair"
and did not intend abatement to "be used routinely to avoid
payment of interest". H. Rept. 99-426, at 844 (1985),
1986-3 C.B. (Vol. 2) 1, 844; S. Rept. 99-313, at 208
(1986), 1986-3 C.B. (Vol. 3) 1, 208.
In this case, as discussed above, petitioner seeks the
abatement of interest that was assessed with respect to
petitioner’s 1998 and 1999 taxes. Petitioner’s amended
petition asks for the abatement of interest in the amount
of $2,229.58. Petitioner’s response to respondent’s motion
for summary judgment states that “petitioner is now
requesting that * * * $2,669.97, be fully abated.”
According to petitioner’s response, petitioner was not
previously aware of “the entire amount of interest that had
been paid over the years.” In effect, petitioner is asking
for abatement of all of the interest that accrued with
respect to the delay of approximately 60 months in the
payment of her 1998 tax liability, and all of the interest
that accrued with respect to the delay of approximately 48
months in the payment of her 1999 tax liability.
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