MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
The petition in this case was filed in response to a notice of final determination granting in part and denying in part petitioner's claim to abate interest on income tax liabilities for 1983 and 1984 pursuant to section 6404(e). After concessions, the sole issue for decision is whether the failure to abate the balance of the interest was an abuse of discretion.
Unless otherwise indicated, all...
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