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exercised this discretion arbitrarily, capriciously, or without
sound basis in fact or law. Woodral v. Commissioner, supra at
23.
Petitioner does not allege that the interest resulting from
the 1995 residence sale is attributable to any error or delay by
an officer or employee of the IRS in performing a ministerial
act. Therefore, respondent did not abuse his discretion by
failing to abate interest.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011