MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
This case is before the Court for review of respondent's failure to abate interest. Unless otherwise noted, all section references are to the Internal Revenue Code of 1986, as amended.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. At the time they filed the petition, petitioners...
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