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.
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