MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge.
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5) in effect when this case commenced, and Rules 180, 181, and 183. Unless otherwise indicated, section references are to the Internal Revenue Code as in effect for the tax year for which petitioner seeks abatement of interest. All Rule...
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