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Commissioner, T.C. Memo. 2000-220. Such a broad claim extends
beyond the intention of the statute. See H. Rept. 99-426, supra
at 844, 1986-3 C.B. (Vol. 2) at 844; S. Rept. 99-313, supra at
208, 1986-3 C.B. (Vol. 3) at 208. Respondent’s failure to abate
interest based on petitioners’ blanket request was not an abuse
of discretion. See Donovan v. Commissioner, supra.
In their posttrial memorandum petitioners argue that
interest should be abated because they requested the Secretary to
recalculate their income tax liability for 2000, and the
Secretary had all required Forms 1099 and other information to do
so accurately and promptly. Petitioners contend that the act of
processing their 2000 return accurately was a ministerial act.
We disagree. The processing and evaluation of their income tax
return required the application of Federal tax laws, which was
not a ministerial or managerial act.
In this case respondent did not learn that petitioners’ IRA
deduction was erroneous until after he had contacted petitioners
and requested information concerning the deduction. After
petitioners conceded the deduction was erroneous, respondent
promptly recalculated petitioners’ 2000 income tax liability and
notified them of the results. Less than 1 year later, respondent
again contacted petitioners regarding their failure to treat the
entire amount of the retirement distributions as taxable income.
Again respondent acted promptly to determine petitioners’ correct
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