Scanlon White, Inc. - Page 7

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          is not mentioned in section 6211 or section 6212(a).  Woodral v.            
          Commissioner, 112 T.C. at 25.                                               
               As indicated above, petitioner does not argue that it is               
          entitled to abatement of interest under any other subsection of             
          section 6404.  Petitioner has not suggested that the assessments            
          of interest were excessive, erroneous, or illegal.  Cf. Woodral             
          v. Commissioner, 112 T.C. at 24; Law Offices of Michael B. L.               
          Hepps v. Commissioner, T.C. Memo. 2005-138; H&H Trim & Upholstery           
          Co. v. Commissioner, T.C. Memo. 2003-9.  In opposing respondent’s           
          motion for summary judgment, petitioner has not presented any               
          specific facts showing that there is a genuine issue for trial.             
          See Rule 121(d).  Petitioner has not alleged specific facts                 
          showing that delay in the payment of its employment tax                     
          liabilities was attributable to any action or inaction on the               
          part of IRS personnel in processing its offer in compromise.                
          Petitioner was not prevented from making payments while its offer           
          in compromise was pending.  See Wright v. Commissioner, T.C.                
          Memo. 2004-69, affd. 125 Fed. Appx. 547 (5th Cir. 2005).                    
               Following the precedent established in Woodral v.                      
          Commissioner, supra, and Miller v. Commissioner, supra, we                  
          conclude that there was no abuse of discretion in denying                   
          petitioner’s claim for abatement, because the IRS does not have             









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