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example, monies deducted from the Petitioner’s January
2000 paycheck were not applied to the taxes due until
Apr 15, 2001 when the taxes for 2000 were due. Apply-
ing 1/12 of the refund due for tax year 2000 evenly
throughout 2000 as payments against the taxes due would
significantly reduce the interest charge in this case
and more fairly represent the actual amount that should
be owed.
* * * In addition interest in this case is eligible for
abatement because the delayed payments were not due
solely to the actions of the Petitioner, but were
caused by bad advice from a former CPA. [Reproduced
literally.]
We turn first to petitioner’s contention that respondent
abused respondent’s discretion in failing to abate interest on
petitioner’s unpaid total 1999 liability because respondent did
not apply tax withheld from wages that petitioner received during
taxable years after his taxable year 1999 to his unpaid total
1999 liability at the time such tax was withheld. We reject that
contention. As discussed above, any tax withheld from an indi-
vidual’s wages is deemed paid by the individual on the 15th day
of the fourth month following the close of the taxable year with
respect to which such tax is allowable as a credit under section
31. See sec. 6513(b)(1).
We turn next to petitioner’s contention that respondent
abused respondent’s discretion in failing to abate interest on
petitioner’s unpaid total 1999 liability because he received “bad
advice” from a certified public accountant. We reject that
contention. Any advice that petitioner received from a certified
public accountant is not a basis under section 6404(e) on which
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