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and $310.28, respectively. These balances are shown on the
1999 status history of petitioner’s account, which is
attached to petitioner’s amended petition.
There is no basis on which to find that any
unreasonable error or delay in petitioner’s payment of
interest for 1998 and 1999 is attributable to an officer or
employee of the IRS’s being erroneous or dilatory in
performing a ministerial or managerial act. See sec.
6404(e)(1)(B). Petitioner’s allegation that respondent
failed to notify her or communicate during the 10-month
period November 2002 through September 2003 fails to
explain how that contributed to the delay in petitioner’s
payment. We can see no basis for petitioner’s assertion
that respondent was erroneous or dilatory in performing a
ministerial or managerial act. This is especially true in
light of the notices of balance due that respondent issued
for both years shortly before the 10-month period about
which petitioner complains.
Petitioner contends that respondent committed “an
overt abuse of discretion” “by seizing dividends and
placing back-up withholding” on petitioner’s brokerage
account. It is unclear to the Court how respondent’s
efforts to collect petitioner’s taxes contributed to the
delay in petitioner’s payment. Indeed, it appears that the
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