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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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Last modified: November 10, 2007