TERENCE T. EVANS, Circuit Judge.
Edward J. Kunze died on December 18, 1992. The after-tax net worth of his estate at the time of his death was approximately $2.5 million. This amount is uncontested. Nine months after Edward's Estate filed its tax return, an audit, which eventually lasted 21 months, was started. During the long audit, interest of $21,701.57 accrued.
On July 29, 1996, the Estate filed a petition with the IRS requesting an abatement of this interest...
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