- 7 -
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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Last modified: May 25, 2011