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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.
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Last modified: May 25, 2011