- 5 - Further, because the only basis alleged by petitioner for interest abatement is the incorrectness of the underlying tax deficiency determined by respondent, the correctness of which is not properly before us, petitioner raises no viable issue as to her entitlement to interest abatement. We shall grant respondent’s motion for summary judgment as to petitioner’s claim for interest abatement. Also, in our discretion, we shall deny respondent’s motion for a penalty under section 6673. An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5Last modified: March 27, 2008