Tan Xuan Bui - Page 10




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          is a genuine issue as to any material fact or that respondent is            
          not entitled to a decision as a matter of law.6                             
          III. Conclusion                                                             
               We shall grant respondent’s summary judgment motion with               
          respect to petitioner’s abatement claim under section 6404(e)(1).           
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                





















               6 Petitioner’s claim that the settlement in his deficiency             
          case does not speak to the issue of interest is remarkably                  
          disingenuous given the clarity of the language used in the                  
          decision:  “It is further stipulated that interest will be                  
          assessed as provided by law on the deficiencies and penalties due           
          from the petitioner.”                                                       






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