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specific period for which interest should be abated as a result
of that error or delay. Palihnich v. Commissioner, T.C. Memo.
2003-297; Donovan v. Commissioner, T.C. Memo. 2000-220; Douponce
v. Commissioner, T.C. Memo 1999-398.
B. March 18, 1999, to June 25, 2001
1. Alleged Erroneous Advice by Davis
Petitioners contend that Davis erred in recommending that
they file an offer in compromise and that she should have instead
recommended that they address issues concerning telecommunication
expenses when petitioner told her on March 18, 1999, that they
did not include all telecommunication expenses in their original
returns for 1991-95. We disagree that this is an appropriate
basis to consider relief for petitioners because Davis’s advice
(the merit of which we need not consider) requires judgment and
thus was not ministerial. Sec. 301.6404-2T(b)(1), Temporary
Proced. & Admin. Regs., supra.
2. Maternity Leave
Petitioners contend that respondent delayed working on their
case during an unspecified period between March 18, 1999, and
June 25, 2001, because Davis was on maternity leave. We disagree
that this is an appropriate basis to consider relief for
petitioners. Granting maternity leave to an employee of the
Commissioner assigned to the taxpayer’s case without reassigning
the case is not a ministerial act under section 6404(e)(1). Sec.
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