Mark S. & Lois A. Freme - Page 15




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          see also Washington v. Commissioner, 120 T.C. 114, 123-124                  
          (2003).                                                                     
               We turn now to petitioners’ argument regarding respondent’s            
          failure to abate interest under section 6404, which we shall                
          review for abuse of discretion.  See sec. 6404(h); see also Lee             
          v. Commissioner, 113 T.C. 145, 149 (1999).  Section 6404(e)                 
          permits respondent to abate interest with respect to an unreason-           
          able error or delay resulting from managerial and ministerial               
          acts.                                                                       
               Although petitioners allege in the petition that they should           
          be relieved from paying any interest with respect to each of                
          their taxable years 1999 through 2003, petitioners do not advance           
          any contentions or arguments in support of that allegation.  On             
          the record before us, we find that petitioners have failed to               
          show that respondent abused respondent’s discretion in failing to           
          abate interest under section 6404 with respect to each of those             
          years.                                                                      
               Based upon our examination of the entire record before us,             
          we reject respondent’s determination in the notice of determina-            



               3(...continued)                                                        
          failure to abate additions to tax under sec. 6404, on that                  
          record, we hold that the Court does not have jurisdiction to                
          review petitioners’ request that we review any such failure.  See           
          sec. 6404(h); see also Washington v. Commissioner, 120 T.C. 114,            
          124 n.15 (2003); Krugman v. Commissioner, 112 T.C. 230, 237                 
          (1999).                                                                     





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