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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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