MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
The petition in this case was filed in response to a notice of determination denying petitioner's request to abate interest on income tax liabilities for 1982, 1983, and 1984 pursuant to section 6404(e). The issue for decision is whether the failure to abate interest between October 12, 1993, and September or October 1998 was an abuse of discretion.
Unless otherwise indicated, all section references...
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