MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge.
Respondent issued a final determination disallowing petitioners' claim under section 6404(e) for abatement of interest related to their income tax liabilities for 1991-95 that accrued from March 18, 1999, to October 8, 2002.
Respondent concedes that petitioners are entitled to abatement of interest that accrued from June 26 to November 7, 2001. The issue for decision is whether respondent's denial...
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