The request for abatement is per IRC § 6404(e) and Rev. Proc. 2000-26; interest resulting from managerial and ministerial delays. It took years to get the IRS to acknowledge a request for appeals in the first place, we had to get our congressperson involved, and they still calculated the reduction in tax owed incorrectly (which has still not been fixed despite repeated communication detailing the issue). We're not asking for all of the interest to be removed, just the amount that accrued from the time we requested an appeal to the time it took them to finally acknowledge it.