Ralph Howell - Page 6




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               By separate letters dated January 17, 2003, respondent                 
          denied petitioner’s requests for interest abatement.4  Respondent           
          concluded, inter alia, that petitioner did not meet the                     
          requirements of section 6404(e) and that petitioner could not               
          challenge the extensions of the period of limitations on                    
          assessment of AMCOR partnership items in his individual capacity.           
               On May 4, 2005, respondent issued a letter entitled “Full              
          Disallowance--Final Determination” to petitioner denying                    
          petitioner’s request for interest abatement.  In relevant part,             
          that letter stated:                                                         
               We regret that our final determination is to deny your                 
               request for an abatement of interest.  We had to deny                  
               your request for the following reason(s):                              
                    •  We did not find any errors or delays on our                    
                    part that merit the abatement of interest in                      
                    our review of available records and other                         
                    information for the period requested.                             
               On July 15, 2005, petitioner petitioned the Court for review           
          of respondent’s determination.                                              
                                       OPINION                                        
          I.  Section 6404(e)                                                         
               Pursuant to section 6404(e)(1) as it applies in this case,             
          the Commissioner may abate the assessment of interest in two                


               4  The parties did not submit a copy of respondent’s Jan.              
          17, 2003, letter disallowing petitioner’s request for interest              
          abatement with regard to his 1986 deficiency, but the parties               
          stipulated that the contents of that letter were identical in all           
          respects to the letters disallowing petitioner’s requests for               
          interest abatement with regard to his 1984 and 1985 deficiencies.           




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