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as to what happened to the missing returns weighs in favor of
respondent.
Consequently, petitioners are not entitled to an abatement
of interest under section 6404(e) with respect to their 1997
income tax. It follows that respondent’s failure to abate such
interest is not an abuse of discretion.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: March 27, 2008