Scanlon White, Inc. - Page 2

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          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                     Background                                       
               At the time that the petition was filed, petitioner’s                  
          principal place of business was in New Mexico.  On June 19, 2004,           
          petitioner submitted to respondent a request for abatement of               
          interest on its unpaid employment taxes for quarters ended                  
          December 31, 1997, to December 31, 1999.  On August 5, 2004,                
          respondent issued a letter to petitioner citing section                     
          6404(e)(1) for the proposition that respondent lacked the                   
          authority to abate interest due on petitioner’s unpaid employment           
          taxes for quarters ended December 31, 1997, to September 30,                
          1998.  On August 9, 2004, respondent issued similar letters to              
          petitioner with regard to its request for abatement of interest             
          on its unpaid employment taxes for quarters ended December 31,              
          1998, to December 31, 1999.                                                 
               On January 31, 2005, petitioner filed with the Court a                 
          petition for review of failure to abate interest under section              
          6404.  The petition alleges, in part:                                       
               The facts on which petitioner relies to establish that                 
               the Commissioner’s final determination not to abate                    
               interest was an abuse of discretion are as follows:                    







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