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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.
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