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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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Last modified: March 27, 2008