David and Monika Zisskind - Page 13

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               Petitioners have not shown that respondent caused any                  
          unreasonable error or delay in the evaluation of their offer-in-            
          compromise forms submitted on November 27, 2002.  Moreover, any             
          delays in processing the offer-in-compromise were attributable in           
          significant part to petitioners’ failure to provide the revenue             
          officer with requested information or clarification of other                
               Petitioners’ assertion that respondent failed to meet with             
          them to resolve this case despite several attempts by petitioners           
          to do so is without support.  Petitioners provided no specific              
          information regarding who they tried to contact or when.                    
          Additionally, Ms. Russo’s casenotes indicate that she promptly              
          responded to all telephone calls and correspondence.                        
               Petitioners have failed to establish that respondent caused            
          any unreasonable errors or delays in the performance of a                   
          ministerial or managerial act.  Therefore, petitioners have                 
          failed to show that respondent abused his discretion by rejecting           
          their request for an abatement of interest.  We hold that                   
          respondent did not abuse his discretion by rejection petitioners’           
          request for an abatement of interest.                                       
          C.   Appropriateness of the Federal Tax Lien                                
               During their section 6330 hearing, petitioners requested               
          that respondent release the Federal tax lien.  However,                     
          petitioners did not allege in their petition that respondent                

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Last modified: November 10, 2007