Jesse and Tawara Goode - Page 18

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          respondent does not provide notice to the taxpayer identifying              
          the particular amount due and the basis for the liability within            
          a specified 18-month period.  The applicable 18-month period                
          commences on the later of the due date of the return or the date            
          the return was filed (without regard to extensions).  Sec.                  
          6404(g)(1)(A).  The temporary suspension of interest runs from              
          the day after the close of the 18-month period to the date which            
          is 21 days following respondent’s issuance of the explanatory               
          notice.  Sec. 6404(g)(3).                                                   
               Respondent argues that jurisdiction to consider petitioner’s           
          interest claim is not available here pursuant to section 6404(b),           
          which generally proscribes judicial review of claims for                    
          abatement of an assessment of interest on income, estate or gift            
          tax.  See Rev. Proc. 2005-38, 2005-28 I.R.B. 81.                            
               It is respondent’s further contention that jurisdiction over           
          petitioner’s claim concerning suspension of interest under                  
          section 6404(g) does not fall within the narrowly circumscribed             
          exception to section 6404(b) provided in section 6404(h).                   
          Section 6404(h) authorizes jurisdiction over actions timely                 
          brought by a taxpayer (who meets the requirements of section                
          7430(c)(4)(A)(ii)) challenging a final determination of                     
          respondent concerning a claim for abatement of interest.                    
          Respondent’s delegated scope of administrative review to consider           
          interest abatement claims under section 6404(e) is confined to              






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