Scanlon White, Inc. - Page 1

                                 T.C. Memo. 2005-282                                  

                               UNITED STATES TAX COURT                                

                         SCANLON WHITE, INC., Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1958-05.             Filed December 6, 2005.                

               John Edward Leeper, for petitioner.                                    
               Dennis R. Onnen, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               COHEN, Judge:  This case is before the Court on respondent’s           
          motion for summary judgment.  The issue for decision is whether             
          there was an abuse of discretion by the Internal Revenue Service            
          (IRS) in failing to abate interest on employment taxes.                     
          Respondent relies on our decision in Woodral v. Commissioner, 112           
          T.C. 19 (1999), and petitioner disagrees with that opinion.                 

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