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2000, and petitioner did not file a timely petition.
Accordingly, we review the determination for abuse of discretion.
Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114 T.C. 176, 181 (2000). Petitioner did not raise
collection alternatives or argue that the failure of respondent
to accept the OIC was an abuse of discretion. Accordingly, we
need not consider whether the Appeals officer’s refusal to accept
the OIC submitted by petitioner was arbitrary, capricious, or
without sound basis in fact or law. The only issues appear to be
an abatement of interest and an addition to tax.
I. Abatement of Interest
If, as part of a section 6330 proceeding, a taxpayer makes a
request for abatement of interest, we have jurisdiction over the
taxpayer’s request for abatement that is the subject of the
Commissioner’s collection activities. Katz v. Commissioner, 115
T.C. 329, 340-341 (2000); Moore v. Commissioner, 114 T.C. 171,
175 (2000). This Court may order an abatement of interest if the
Commissioner abuses his discretion in failing to abate interest.
Sec. 6404(i)(1). The taxpayer must show that the Commissioner
exercised his discretion arbitrarily, capriciously, or without
sound basis in fact or law. Woodral v. Commissioner, 112 T.C.
19, 23 (1999).
As applicable for the year in issue, section 6404(e) permits
the Commissioner to abate interest with respect to any
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