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301.6404-2T(b)(1), Temporary Proced. & Admin. Regs., 52 Fed. Reg.
30163 (Aug. 13, 1987); sec. 301.6404-2, Proced. & Admin. Regs.
In contrast, a “managerial act” is an administrative act
that occurs during the processing of a taxpayer’s case and that
involves the temporary or permanent loss of records or the
exercise of judgment or discretion relating to management of
personnel. Sec. 301.6404-2(b)(1), Proced. & Admin. Regs.
Congress did not intend the interest abatement statute to be
used routinely. Accordingly, we grant abatement only “where
failure to abate interest would be widely perceived as grossly
unfair.” Lee v. Commissioner, supra; 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. Further, the mere passage
of time does not establish an error or delay by the Commissioner.
See Lee v. Commissioner, supra at 150.
Petitioner contends that respondent committed several errors
in processing his offers in compromise. These errors, petitioner
asserts, include respondent’s conflicting requests for an
information return, and respondent’s request for all the Brauns’
investment account information when respondent had earlier
requested only 401(k) information. In addition, petitioner
alleges that respondent falsely claimed that petitioner did not
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