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deficiency. Petitioner has alleged, therefore, no ministerial
delays in this case.
Managerial errors or delays, on the other hand, include
situations involving the loss of records or the exercise of
judgment relating to management of personnel. See sec. 301.6404-
2(c), Proced. & Admin. Regs. Delays involving the exercise of
such judgment may result from the Commissioner sending an IRS
agent to training or granting sick leave to an agent for an
extended period without reassigning the agent’s cases. See sec.
301.6404-2(c), Examples (3), (4), (5), (10), Proced. & Admin.
Regs.
Petitioner alleges that respondent committed a managerial
mistake in requesting that petitioner submit a Form 433-F, then
requesting that petitioner submit Form 433-A, which is
substantially longer. One month after respondent requested the
longer form, however, respondent told petitioner that he would
proceed with his determination based upon the shorter form, as
petitioner requested. The delay, therefore, was not longer than
a month.
Moreover, an abatement of interest is not warranted where a
significant aspect of the delay is attributable to petitioner.
See sec. 6404(e)(1); sec. 301.6404-2(c), Example (13), Proced. &
Admin. Regs. Here, petitioner originally submitted his offer in
compromise without proper forms, he increased the amount of his
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