MEMORANDUM OPINION
COHEN, Judge.
On November 12, 1998, respondent issued a notice of final determination denying petitioner's claim for abatement of interest. Petitioner filed a petition under section 6404(i) and Rule 280. The case is before the Court on respondent's motion for summary judgment. The issue for decision is whether respondent has the authority to abate interest on employment taxes under section 6404(e)(1)(A). Unless otherwise indicated, all...
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