- 12 - respondent issued the letter of January 20, 1997, the case was before this Court when the letter was issued. As the letter correctly noted, the period of limitations on assessment of deficiencies in petitioner’s taxes was consequently suspended. See sec. 6229(d)(1). Petitioner has not shown that respondent’s letter of January 20, 1997, caused any accrual of interest that is attributable to error or delay in performing a ministerial act. Petitioner further contends that the error contained in respondent’s letter of January 20, 1997, provides an independent basis for the abatement of interest pursuant to section 6404(f). Generally speaking, section 6404(f) allows for the abatement of penalties and additions to tax, and not of assessments of interest.9 See sec. 301.6404-3(c)(2), Proced. & Admin. Regs. Petitioner’s argument regarding section 6404(f) is therefore unfounded. Finally, petitioner argues that respondent lost some of the documents that respondent seized in March of 1989 from AMCOR’s office and that respondent returned other documents in a state of disarray. Petitioner appears to argue that respondent is collaterally estopped from denying such facts pursuant to 9 Sec. 6404(f) does allow for abatement of interest imposed with respect to any penalty or addition to tax. See sec. 301.6404-3(c)(2), Proced. & Admin. Regs. Such interest is not at issue in the matter before us.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007