No. 90-8225.

936 F.2d 548 (1991)

HORTON HOMES, INC., N.D. Horton, Jr., Jacqueline P. Horton, N.D. Horton, Sr. and Maude Horton, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

July 23, 1991.

Attorney(s) appearing for the Case

David D. Aughtry, George L. Murphy, Jr., Chamberlain, Hrdlicka, White, Johnson & Williams, Atlanta, Ga., Shelly Cashion, Chamberlain, Hrdlicka, White, Johnson & Williams, Houston, Tex., for plaintiffs-appellants.

Frank L. Butler, Asst. U.S. Atty., Macon, Ga., Gary E. Allen, Lead Counsel, Chief, Francis M. Allegra, Brian C. Griffin, Ann B. Durney, Jonathan S. Cohen, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellant.

Before TJOFLAT, Chief Judge, CLARK, Circuit Judge, and KAUFMAN, Senior District Judge.

FRANK A. KAUFMAN, Senior District Judge:

This appeal raises questions concerning the abatement of interest by the Internal Revenue Service (IRS) on income tax deficiencies. Prior to 1986, the IRS did not "generally have the authority to abate interest charges where the additional interest has been caused by IRS errors and delays."1

Effective January 1, 1986, the Congress enacted what is now 26 U.S.C. § 6404(e)(1). That statute...

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