Marjorie Cathey Miller - Page 7

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            Thus, we must conclude that, in using the term “deficiency” in                             
            section 6404(e)(1)(A), Congress intended only that respondent                              
            have authority to abate interest with respect to income, estate,                           
            gift, generation skipping, and certain excise taxes and not with                           
            respect to employment taxes.  See sec. 6211.                                               
                  In this case, petitioner seeks to have interest relating to                          
            employment tax liabilities abated under section 6404(e).                                   
            Following the precedent established in Woodral v. Commissioner,                            
            supra, we conclude that respondent did not commit an abuse of                              
            discretion in this case by denying petitioner’s claim for                                  
            abatement because respondent does not have the authority under                             
            section 6404(e) to abate interest on employment taxes.  See                                
            Woodral v. Commissioner, supra at 25.                                                      
                  To reflect the foregoing,                                                            
                                                            Respondent’s motion will                   
                                                      be granted, and decision will                    
                                                      be entered for respondent.                       

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