MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined that petitioner is not entitled to an abatement of interest under section 6404(e)(1) on petitioner's Federal income tax deficiencies for 1983, 1984, and 1985.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue for...
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