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make a reasonable attempt to comply with the law and disregard of
the rules and regulations includes any "careless, reckless, or
intentional disregard." Sec. 6662(c). While we have sustained
respondent's determinations with respect to the savings plan
distribution includable in gross income and the additional tax
under section 72(t), we do not believe that the understatement of
tax was due to negligence. It appears that petitioner was not
given a Form 1099R or any other notice that the withdrawal was
taxable prior to filing his return. As we understand, petitioner
thought that the withdrawal of his contribution and the earnings
thereon were exempt. While he was incorrect, we recognize that
there may be room for confusion.
Interest
Petitioner argues that we should abate the interest
determination made by respondent pursuant to section 6404(e)
because of respondent's delay in issuing the notice of
deficiency. The United States Tax Court is a court of limited
jurisdiction. See sec. 7442; Wilt v. Commissioner, 60 T.C. 977,
978 (1973). New section 6404(g), added to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure
to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jurisdiction to abate
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