On March 28, 2022, the Tax Court issued a Memorandum Opinion in the case of Porter v. Commissioner (T.C. Memo. 2022-25). The primary issues presented in Porter v. Commissioner were whether (i) delays in examination and litigation were attributable to IRS officer or could significantly be attributed to taxpayer; and (ii) whether the interest on a deficiency settlement should be abated. Held: Not today, Jeremy. Porter v. Commissioner (Very) Briefly The IRS audited the petitioner’s 2011 and 2012 taxes, issuing a notice of deficiency in 2014, in response to which the petitioner timely filed a Tax Court petition, which was ultimately settled in 2019. The petitioner paid $1,720 of interest on the stipulated deficiency for 2011 on or around August 12, 2019, and $1,349 of interest on the stipulated deficiency for 2012 on or around February 3, 2020. The Request for Abatement of Interest On or around October 19, 2019,…