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offer twice, he canceled one conference with respondent and
refused others, and he failed to submit all the information that
respondent requested. We find that these actions constituted a
significant cause of the delay in processing petitioner’s offers
in compromise. Petitioner’s remaining allegations that
respondent misled him, discriminated against him, and retaliated
against him are not supported by the record.
2. Whether Petitioner Established a Correlation Between a
Specific Period of Delay in Payment and an Error or Delay by
Respondent
Further, section 6404(e) requires that petitioner not only
identify a mistake by respondent, but link the mistake to a
specific period of delay in payment for which interest should be
abated. Petitioner has alleged no specific period during which
interest should be abated, other than objecting generally to all
interest flowing from the Brauns’ tax liabilities for 1994 and
1997.
The requisite correlation between an error or delay
attributable to the Commissioner and a specific period of time
is, for the most part, missing where a taxpayer requests that all
interest with respect to the deficiencies be abated. See Donovan
v. Commissioner, T.C. Memo. 2000-220. Petitioner’s request
amounts to a claim for an exemption from interest, rather than a
claim for abatement of interest. Id. Congress did not intend
the statute to be used “routinely to avoid payment of interest.”
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Last modified: May 25, 2011