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is no statutory authority that supports the abatement of such
interest, respondent’s failure to abate is hardly an abuse of
discretion. Therefore, respondent’s failure to abate interest
that accrued prior to January 16, 1997, is not an abuse of
discretion.
Interest From January 16, 1997 Through June 30, 1998
As of January 15, 1997, petitioner, in good faith,
considered its Federal employment tax liability for the fourth
quarter of 1993 to have been completely satisfied upon payment of
the amount specified by respondent’s employee. As of
June 30, 1998, it was clear to petitioner that the January 15,
1997, payment did not entirely extinguish its Federal employment
tax liability for the fourth quarter of 1993 because that payment
did not include interest that had accrued but had not been
assessed as of the payment date.
Under the circumstances, we are satisfied that, but for
respondent’s error, petitioner’s then-outstanding Federal
employment tax liability for the fourth quarter of 1993 would
have been completely paid on January 15, 1997. Had petitioner
completely paid its employment tax liability on January 15, 1997,
no additional interest would have accrued.
Although the point is not specifically conceded, respondent
makes little attempt to persuade us that, under these
circumstances, it would not be unfair to charge petitioner with
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