- 13 - tax liability is not properly placed at issue, the Court will review the determination of the Commissioner of Internal Revenue for abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). Based upon our examination of the entire record before us, we find that, except for the determinations relating to respon- dent’s assessment for petitioners’ taxable year 1988 of excessive amounts of the addition to tax under section 6653(a) and interest thereon that respondent conceded,3 respondent did not abuse respondent’s discretion in making the determinations in the notice of determination under sections 6320 and 6330 with respect to petitioners’ taxable year 1988. We have considered all of the contentions and arguments of the parties that are not discussed herein, and we find them to be without merit, irrelevant, and/or moot. On the record before us, we shall grant respondent’s motion. To reflect the foregoing, An order granting respondent’s motion and an appropriate decision for respondent will be entered. 3In respondent’s motion, respondent states: “Respondent has taken the necessary steps to abate the [$67,978.11] excess penalty (i.e., to the extent that it exceeds $2,777.50) and interest thereon.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13Last modified: November 10, 2007