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Further, because the only basis alleged by petitioner for
interest abatement is the incorrectness of the underlying tax
deficiency determined by respondent, the correctness of which is
not properly before us, petitioner raises no viable issue as to
her entitlement to interest abatement.
We shall grant respondent’s motion for summary judgment as
to petitioner’s claim for interest abatement.
Also, in our discretion, we shall deny respondent’s motion
for a penalty under section 6673.
An appropriate order and
decision will be entered for
respondent.
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Last modified: March 27, 2008