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amount to refinance their home to pay their tax liabilities.
Respondent sent petitioners a computer printout for each year
disclosing their total outstanding tax liabilities, including
interest and additions to tax. Petitioners, however, did not
submit a loan application for the refinancing of their home until
almost 4 months later on or about July 14, 2003, which was
rejected on July 16, 2003, because of petitioners’ poor
performance with World Savings.7 From March 27 until on or about
July 16, 2003, there was no erroneous or dilatory performance of
a ministerial act by respondent, nor was there any unreasonable
error or delay resulting from any managerial or ministerial act
that contributed to a delay in the payment of petitioners’ tax
liabilities. Under these circumstances, respondent did not abuse
his discretion to refuse to abate interest that accrued for that
period.
For the period July 31 to November 30, 2003, respondent
determined that “there was some delay in providing the taxpayer’s
[sic] timely information regarding the amounts due on their
delinquent income tax liabilities”.8 It is reasonable to assume
that the delay in the payment of petitioners’ tax liabilities for
7 Petitioners allege that World Savings rejected their loan
application because of the lien. The allegation, however, is
unproven.
8 There is no explanation in the record as to the
significance of July 31, 2003.
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