William and Helen Woodral - Page 1

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                                   112 T.C. No. 3                                     


                               UNITED STATES TAX COURT                                


                      WILLIAM AND HELEN WOODRAL, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6385-98.                  Filed January 12, 1999.           


                    Ps submitted to the IRS a request for abatement of                
               interest relating to employment taxes.  R issued to Ps                 
               a notice of final determination not to abate interest.                 
               Ps filed a petition for review of R's failure to abate                 
               interest.                                                              
                    Held:  R's failure to abate the assessments of                    
               interest under sec. 6404(a), I.R.C., was not an abuse                  
               of discretion.                                                         
                    Held, further:  Sec. 6404(e)(1), I.R.C., does not                 
               authorize R to abate assessments of interest on                        
               employment taxes; therefore, R's failure to abate the                  
               assessments of interest under sec. 6404(e), I.R.C., was                
               not an abuse of discretion.                                            

               Robert C. Platt, for petitioners.                                      
               Usha Ravi and Ronald G. Dong, for respondent.