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OPINION OF THE SPECIAL TRIAL JUDGE
CARLUZZO, Special Trial Judge: On September 24, 1999,
respondent issued a notice of final determination denying
petitioner’s request to abate interest related to employment
taxes for the fourth quarter of 1993. Petitioner filed a timely
petition for review with this Court. Our jurisdiction is
established by section 6404(h).2 The issue for decision is
whether respondent’s failure to abate interest with respect to
petitioner’s employment tax liability for the fourth quarter of
1993 is an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner was incorporated in Florida in 1986. At the time the
petition was filed, petitioner’s principal place of business was
located in Sarasota, Florida. At all relevant times, Dane R.
Halse served as petitioner’s president.
On or about January 31, 1994, petitioner filed with the
Internal Revenue Service a timely Form 941, Employer’s Quarterly
Federal Tax Return (Form 941), for the quarter ending December
31, 1993, reflecting a tax liability of $5,304.09. Petitioner
made no deposits of employment tax during the fourth quarter of
1993, and it did not send in any payments with its tax return for
2 Previously designated sec. 6404(i). See Victims of
Terrorism Tax Relief Act of 2001, Pub. L. 107-134, sec.
112(d)(1)(B), 115 Stat. 2435.
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Last modified: May 25, 2011