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act. In fact, our review reflects that respondent followed
regular IRS procedures in processing petitioner’s various offers
in compromise and that interest accruals for 1994 and 1997 were
merely the result of petitioner’s failure to pay the entire
balance owed. We therefore conclude that respondent did not
abuse his discretion by denying petitioner’s request to abate
interest on the Brauns’ unpaid tax liabilities for 1994 and 1997.
Accordingly, we sustain respondent’s determination.
In reaching our holding, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011