Yvonne Thomas - Page 5




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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