Seymour and Beatrice Leffert - Page 1
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T.C. Memo. 2001-23
UNITED STATES TAX COURT
SEYMOUR AND BEATRICE LEFFERT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18802-98. Filed January 31, 2001.
Seymour Leffert, pro se.
Thomas J. Kerrigan, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: On September 18, 1998, respondent issued a
notice of final determination disallowing petitioners’ claim for
abatement of interest relating to petitioners’ 1982 and 1983
taxable years. Petitioners timely filed a petition under section
6404(g)1 and Rule 280.2 The only issue for decision is whether
1Sec. 6404(g) was redesignated sec. 6404(i) by the Internal
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