- 6 -
unreimbursed employee expenses for travel. Petitioner,
therefore, is not allowed a deduction for these expenses.
Finally, petitioner contends that the interest due on any
deficiency under section 6601 should be abated. With the
exception of a limited grant of jurisdiction under section
7481(c), this Court has no jurisdiction to abate or reduce
interest on deficiencies and thus is unable to afford the
requested relief. Standard Oil Co. v. McMahon, 244 F.2d 11, 13
(2d Cir. 1957); Rutland v. Commissioner, 89 T.C. 1137, 1155
(1987); LTV Corp. v. Commissioner, 64 T.C. 589, 597 (1975);
Hudgins v. Commissioner, 55 T.C. 534, 538 (1970). Section
7481(c), by its very terms, is inapplicable in this case. Under
that limited grant of jurisdiction, the Tax Court may reopen a
closed case under limited circumstances solely to determine if
the amount of statutory interest calculated by the Commissioner
and paid by the taxpayer was correctly computed. Bax v.
Commissioner, 13 F.3d 54, 58 (2d Cir. 1993).
Section 6404(e)(1)(A) provides generally that the Secretary
may abate the assessment of all or any part of the interest on
any deficiency attributable in whole or in part to any error or
delay by any officer or employee of the Internal Revenue Service,
acting in his official capacity, in performing a ministerial
act. In 508 Clinton Street Corp. v. Commissioner, 89 T.C. 352,
354-355 (1987), it was held that this Court has no jurisdiction
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