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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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