Edward H. Jones, III - Page 30




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          the delay in paying the taxes due per his tax return, and so that           
          is not a basis for denying petitioner’s claim for abatement of              
          interest.  Nevertheless, petitioner will not succeed in most of             
          his abatement claim for reasons set forth in the preceding                  
          portions of this opinion granting in part respondent’s summary              
          judgment motion.  Also, as we have made plain, our ruling against           
          part of respondent’s summary judgment motion is not a ruling for            
          petitioner on any part of the underlying claim.                             
               To take account of the foregoing,                                      

                                                  An appropriate order will           
                                             be issued granting in part and           
                                             denying in part respondent’s             
                                             motion for summary judgment.             
























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