- 30 - 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30Last modified: March 27, 2008