- 13 - However, because respondent did not adequately consider section 6404(a) in making his final determination that petitioner was not entitled to an abatement of interest under section 6404 and because there is a dispute regarding the material facts, we are unable to conclude that respondent is entitled to summary judgment with respect to section 6404(a). See H & H Trim & Upholstery Co. v. Commissioner, T.C. Memo. 2003-9. To reflect the foregoing, An appropriate order will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011