Bernard A. Kansky - Page 23

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            forcing respondent to take action to secure the filing of the                               
            returns.  Because of petitioner’s lack of cooperation, respondent                           
            eventually resorted to summoning petitioner’s records.  As                                  
            previously noted, it was not until 1996 that petitioner finally                             
            submitted his delinquent returns for 1987 through 1991.  Notably,                           
            petitioner’s accompanying cover letter attributed the late                                  
            submission to his health problems rather than to any error or                               
            delay by respondent’s employees; petitioner’s letter thanked the                            
            IRS agents for their “professionalism and patience”.                                        
                  In sum, petitioner has not shown that respondent abused his                           
            discretion in failing to comply with petitioner’s request for                               
            interest abatement.                                                                         
                  We have considered all arguments made by petitioner and have                          
            found those arguments not discussed herein to be moot or without                            
            merit.13                                                                                    
                  To reflect the foregoing,                                                             

                                                             Decisions will be entered                  
                                                       for respondent.                                  




                  13 Although petitioner alleges in his petition that an IRS                            
            agent advised him not to be concerned about interest, which was                             
            “incorrect”, petitioner has not expressly raised this issue at                              
            trial or on brief.  We deem petitioner to have abandoned any such                           
            issue.  In any event, the record contains no evidence                                       
            corroborating this claim.                                                                   





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